Form OIP NTC Files Dataset

The Form OIP NTC Files Dataset is a corpus of SEC-issued Notices of Application announcing that an insurance company or its registered separate accounts has filed a Form 40-OIP application under the Investment Company Act of 1940 — most often seeking an order under Section 26(c) approving the substitution of one underlying fund for another inside variable annuity or variable life contracts. Each record is the EDGAR accession number folder for a single notice and contains a metadata.json capturing the EDGAR header alongside the substantive notice PDF that the Commission lodged for that accession. The notices are produced by the SEC's Division of Investment Management under delegated authority, not by the applicant, and are published to give interested persons an opportunity to request a hearing or comment before the Commission acts. The dataset covers all Form OIP NTC filings submitted to EDGAR from April 2009 to the present and is distributed as monthly ZIP containers carrying PDF and JSON files.

Update Frequency
Daily
Updated at
2026-04-15
Earliest Sample Date
2009-04-01
Total Size
10.5 MB
Total Records
54
Container Format
ZIP
Content Types
PDF, JSON
Form Types
OIP NTC

Dataset APIs

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.

Download Entire Dataset:

Download a single container file (e.g. monthly archive) from the dataset.

Download Single Container:

Dataset Files

40 files · 10.5 MB
Download All
2021-06.zip5.2 MB1 records
2020-10.zip155.0 KB1 records
2020-01.zip205.4 KB1 records
2019-10.zip170.8 KB1 records
2019-07.zip214.5 KB1 records
2018-12.zip137.6 KB1 records
2018-06.zip148.3 KB1 records
2017-03.zip1.1 MB4 records
2017-01.zip20.4 KB1 records
2016-08.zip49.4 KB1 records
2016-07.zip73.4 KB1 records
2015-05.zip109.7 KB1 records
2015-02.zip31.7 KB1 records
2014-11.zip72.1 KB1 records
2014-08.zip42.4 KB1 records
2014-04.zip50.0 KB1 records
2014-03.zip62.0 KB1 records
2013-06.zip25.3 KB1 records
2013-04.zip119.5 KB1 records
2013-03.zip113.8 KB1 records
2013-02.zip116.9 KB1 records
2013-01.zip46.6 KB1 records
2012-12.zip90.3 KB2 records
2012-08.zip107.2 KB1 records
2012-03.zip172.4 KB1 records
2011-09.zip86.6 KB1 records
2011-07.zip79.2 KB1 records
2011-06.zip109.6 KB2 records
2011-05.zip57.8 KB1 records
2011-03.zip253.2 KB3 records
2010-12.zip221.8 KB2 records
2010-10.zip73.5 KB1 records
2010-08.zip390.4 KB2 records
2010-07.zip77.1 KB2 records
2010-06.zip78.8 KB2 records
2010-04.zip52.7 KB1 records
2010-03.zip57.3 KB1 records
2009-10.zip40.6 KB1 records
2009-09.zip133.2 KB2 records
2009-04.zip187.9 KB3 records

What This Dataset Contains

This dataset packages the SEC's public Notice of Application releases issued under EDGAR form type OIP NTC. Each notice announces that an application on Form 40-OIP has been received and is under consideration, identifies the requested relief — almost always a Section 26(c) order approving a fund substitution within an insurance-company separate account, or a Section 6(c) exemption necessary to effect such a substitution — and opens the statutorily required notice-and-comment period during which interested persons may request a hearing.

Coverage runs from April 2009 to the present and includes every Form OIP NTC submitted to EDGAR over that span. Because the document is issued by the Commission, each accession is lodged under the SEC's internal filer CIK 0009999999997, while the substantive applicant identity — typically a U.S. life insurance company together with one or more of its registered separate accounts, and sometimes an affiliated investment adviser or principal underwriter — sits inside the entities block of the metadata. The dataset bundles the notice PDF and a flat JSON metadata file for each accession; image files and the SGML-wrapped complete-submission .txt are deliberately not included, though URLs back to the EDGAR-hosted versions are preserved in the metadata.

The dataset is distributed as monthly ZIP archives organised by year, with file types limited to PDF and JSON. OIP NTC volume is low and the container calendar is sparse: months with no notices have no archive at all.

Content Structure of a Single Record

What one record represents

One record is the contents of a single EDGAR accession-number folder for a Commission-issued Notice of Application under EDGAR form type OIP NTC. Concretely, that means a metadata.json capturing the EDGAR header for the accession together with the substantive notice document — in practice a single PDF — lodged on EDGAR for that accession. Image files are excluded.

The unit of record is one accession number, i.e. one notice. It is not one applicant, not one fund substitution, not one separate account, and not one calendar event. When a single notice covers several applicants (an insurance company plus one or more of its registered separate accounts, plus an affiliated investment adviser or principal underwriter), or when one notice deals with multiple substitutions, those are aggregated within that one notice and surface in the dataset as one record.

The underlying SEC document

The underlying document is an SEC-issued Notice of Application: the Commission's public announcement that an application on Form 40-OIP has been received under the Investment Company Act of 1940, that the Commission is considering granting the requested order, and that interested persons may request a hearing within a stated deadline. The relief sought is almost always one of two related kinds:

  • an order under Section 26(c) approving the substitution of one underlying fund for another within an insurance-company separate account that funds variable annuity or variable life contracts; or
  • an order under Section 6(c) granting an exemption from one or more provisions of the Act (frequently Sections 2(a)(32), 22(c), 26(c), 27(i)(2)(A), and Rule 22c-1) needed to effect such a substitution, to consolidate accounts, or to wind down a small or closed separate account.

The notice is produced by the Division of Investment Management under delegated authority and is signed by an Assistant Secretary or Deputy Secretary of the Commission, not by the applicant. Because the document is issued by the Commission, the EDGAR accession is lodged under the SEC's internal filer CIK 0009999999997 (visible as the leading 9999999997 segment of the accession number), while the substantive applicant identity sits in the entities block of the metadata — typically an insurance company together with one or more of its registered separate accounts, and sometimes an affiliated adviser or distributor.

The Notice of Application is paired in the Commission's workflow with a later Form OIP ORDR order disposing of the application; the order is filed under a separate form type and is not part of this dataset.

Container and record layout

The dataset is distributed as monthly ZIP archives organised by year. The download URL is https://api.sec-api.io/datasets/form-oip-ntc-files.zip, and within the dataset namespace archives follow the path pattern YYYY/YYYY-MM.zip. OIP NTC volume is low, so the container calendar is sparse: months with no notices have no archive at all.

Inside one monthly archive the top-level folder is named for the calendar month (YYYY-MM/). Beneath it, each filing occupies a subfolder whose name is the EDGAR accession number with all dashes stripped — accession 9999999997-17-000412 becomes the folder 999999999717000412/. Each accession folder contains:

  • a metadata.json file (always present) describing the EDGAR header for the accession;
  • the substantive EDGAR submission document — for OIP NTC, in practice a single PDF carrying the full text of the Notice of Application.

The file-types found in the dataset are PDF and JSON only. HTML renditions, the SGML-wrapped .txt complete submission, XBRL data, and image files are not bundled; URLs back to the EDGAR-hosted versions of those artefacts are preserved inside metadata.json for reference.

The metadata.json schema

metadata.json is a single flat JSON object. Its top-level keys are:

  • formType — EDGAR form type. Always "OIP NTC" for this dataset.
  • accessionNo — canonical 18-digit EDGAR accession number with dashes (e.g. "9999999997-17-000412"). The leading 9999999997 segment indicates the SEC's internal filer CIK.
  • filedAt — EDGAR acceptance timestamp as an ISO-8601 string with timezone offset (e.g. "2017-01-27T15:05:28-05:00").
  • description — short human-readable form description, typically "Form OIP NTC - 40-OIP Notice".
  • linkToFilingDetails — URL to the primary PDF on sec.gov/Archives/.... The same PDF is stored locally inside the accession folder.
  • linkToTxt — URL to the SGML-wrapped complete submission .txt on EDGAR. The .txt itself is not bundled.
  • linkToHtml — URL to the EDGAR -index.htm filing-index page.
  • linkToXbrl — empty string. OIP NTC notices carry no XBRL.
  • id — internal dataset record identifier (a 32-character md5-shaped hex string).
  • documentFormatFiles — array of objects, one per attached document; mirrors EDGAR's "Document Format Files" table.
  • entities — array of objects, one per filer/applicant entity; mirrors EDGAR's "Filer" panel.
  • seriesAndClassesContractsInformation — array, reserved for series/class registration data; routinely empty for OIP NTC.
  • dataFiles — array, reserved for ancillary data files (XBRL, etc.); routinely empty for OIP NTC.

documentFormatFiles entries

Each element of documentFormatFiles is an object with sequence, description, documentUrl, type, and size fields. Two entries are typically present:

  1. The substantive notice PDF. sequence "1", type "OIP NTC", documentUrl pointing to the locally bundled PDF on sec.gov/Archives/..., and size carrying the PDF byte count as a string. This entry corresponds to the PDF stored inside the accession folder.
  2. A trailing entry for the SGML-wrapped complete-submission text file. description "Complete submission text file", documentUrl ending in <accessionNo>.txt, and — distinctively — sequence and type set to a single-space string (" ") acting as a sentinel for "not numbered" / "no document type". The referenced .txt is not bundled in the ZIP.

Numeric fields (size, and filmNo below) are stored as JSON strings rather than as numbers.

entities entries

Each entity object describes one applicant or filer panel from the EDGAR header. Populated fields typically include:

  • companyName — the applicant's name with a parenthetical role suffix appended, e.g. "ALLSTATE ASSURANCE CO SEPARATE ACCOUNT B (Filer)".
  • cik — zero-padded 10-digit CIK of the applicant (not the SEC filer CIK).
  • fileNo — the Investment Company Act file number, in the 812-XXXXX series. The same number appears on the notice's release line and is the stable identifier of the underlying application.
  • irsNo — IRS employer identification number, digits only.
  • fiscalYearEnd — four-character MMDD string (e.g. "1231").
  • act — Securities act code, "40" for the Investment Company Act of 1940.
  • type — the form type as it appears in the entity panel, "OIP NTC".
  • filmNo — EDGAR film number, stored as a string.

When a notice covers multiple applicants, each appears as its own object inside entities — typically one for the insurance company depositor, one for each affected registered separate account, and one for any affiliated investment adviser or principal underwriter named as a co-applicant.

Routinely empty structures

For OIP NTC, three structures are reliably empty rather than missing: linkToXbrl is an empty string, and seriesAndClassesContractsInformation and dataFiles are empty arrays. These reflect real properties of OIP NTC notices — they carry no XBRL, no series/class registration table, and no ancillary data files — and can be treated as expected absences rather than as data anomalies.

The notice PDF

The substantive content of the record is the notice PDF itself, typically running roughly five to fifteen pages. The on-disk filename is frequently the EDGAR placeholder filename1.pdf because filers often do not specify a document name; the substantive document should therefore be located via documentFormatFiles[0].documentUrl and type === "OIP NTC" rather than by filename pattern. The PDF is a verbatim Commission-issued Notice of Application with the following internal anatomy.

Header block

The first page opens with SECURITIES AND EXCHANGE COMMISSION centred at the top, followed by:

  • the Investment Company Act release number in the form Release No. IC-XXXXX (occasionally accompanied by a Securities Act release number when the relief implicates the 1933 Act);
  • the Investment Company Act file number in the 812-XXXXX series, matching the fileNo field in the entity metadata;
  • a case caption naming the applicant(s), commonly in the pattern <Applicant>, et al.; Notice of Application;
  • the date of the release.

Labelled summary paragraphs

The notice then walks through a formulaic sequence of labelled paragraphs that act as structured front matter for the application. The labels are stable across notices and serve as reliable extraction anchors:

  • Agency — almost invariably "Securities and Exchange Commission ('Commission')."
  • Action — short statement of what is being noticed, typically "Notice of an application" under Section 6(c) and/or Section 26(c) of the Investment Company Act of 1940 (the "Act").
  • Applicants — enumerates the applying entities: insurance company, separate account(s), and any affiliated investment adviser or principal underwriter.
  • Summary of Application — one or two paragraphs describing the relief sought. For substitutions, this identifies the existing ("Replaced") and proposed ("Replacement") portfolios and the contracts whose assets will be affected. For exemption-only orders relating to closed or shrinking accounts, it identifies the contracts and explains the proposed deregistration or exemption.
  • Filing Date — the date the application was filed, plus any subsequent amendments. Often followed by language indicating that "Applicants have agreed to file an amendment during the notice period."
  • Hearing or Notification of Hearing — the deadline for hearing requests, expressed as a date and time (commonly 5:30 p.m. Eastern), the address for filing requests, and the manner in which interested persons may be notified of any hearing.
  • Addresses — the Commission's address for service and the applicants' addresses for service of process.
  • For Further Information Contact — the name, division (Division of Investment Management), and telephone number of the staff attorney handling the application.
  • Supplementary Information — a brief pointer to where the full application is available for inspection (Commission's Public Reference Room and EDGAR), often noting that the notice is a summary and that the application itself contains the complete statement.

Roman-numbered substantive sections

After the labelled front matter, the notice transitions into the body of the application as summarised by Commission staff. The body is structured into four Roman-numbered sections:

  • I. Applicants' Representations — the factual narrative provided by the applicants. For substitution applications this details the structure of the separate accounts, the contracts they support, the existing and proposed underlying portfolios, the rationale for the substitution (cost, performance, consolidation, fund mergers, manager turnover), the mechanics of the substitution (in-kind transfer of assets at NAV on the substitution date), and the protections offered to contract owners (no increase in fees for a stated period, free transfers, prospectus delivery, expense limitations). For Section 6(c) exemption-only applications, this section describes the size of the account, the number of contract owners, the historical absence of new sales, and the reasons for non-compliance with the cited provisions.
  • II. Applicants' Legal Analysis — the legal argument supporting the requested relief, citing Section 26(c) (substitution standard: consistent with the protection of investors and the purposes fairly intended by the Act), Section 6(c) (exemption standard: necessary or appropriate in the public interest and consistent with the protection of investors and the purposes fairly intended by the Act), and any related rules (Rule 22c-1, Rule 17a-7 if applicable, Rule 17d-1 if applicable). The analysis applies the cited standards to the represented facts.
  • III. Conditions — numbered conditions on which the applicants have agreed any order may be granted. Common topics include fee caps for a stated period after the substitution, free contract-owner transfers, expense reimbursements, prospectus delivery, and limitations on affiliated transactions.
  • IV. Conclusion — a single paragraph stating that, for the reasons summarised, the relief satisfies the standards of Sections 6(c) and/or 26(c) and should be granted.

Each Roman-numbered section is internally broken into numbered paragraphs that are cross-referenced elsewhere in the notice ("see paragraph II.3 above").

Signature block

The notice closes with a delegated-authority signature block: "For the Commission, by the Division of Investment Management, pursuant to delegated authority," followed by the typed name and title of the signing official (commonly an Assistant Secretary or Deputy Secretary of the Commission). Only the typed signature line is present in the PDF text; no graphical signature image is bundled.

Included content

A record includes:

  • the JSON metadata describing form type, accession number, acceptance timestamp, applicant entity panel(s), the document format file table, and links back to EDGAR-hosted versions of the filing index and complete submission;
  • the notice PDF itself, containing the full verbatim text of the Commission's Notice of Application — header block, labelled summary paragraphs, four Roman-numbered substantive sections, and the delegated-authority signature block.

Where an accession unusually carries more than one substantive document, each is included alongside the metadata; in practice OIP NTC accessions are single-document records.

Excluded or separate content

The dataset deliberately excludes:

  • Image files embedded in or referenced by the EDGAR submission. These are not bundled.
  • The SGML-wrapped complete-submission .txt for the accession. It is referenced by URL in metadata.json (linkToTxt and the trailing documentFormatFiles entry), but the file itself is not stored locally.
  • HTML index renditions of the filing. The EDGAR -index.htm URL is preserved in linkToHtml for reference but not bundled.
  • The underlying Form 40-OIP application itself. The OIP NTC notice summarises and is filed in connection with a separate Form 40-OIP application, which is published under a distinct EDGAR form type and is not included here.
  • Subsequent Form OIP ORDR orders. When the Commission ultimately issues an order on the application (often weeks after the notice), that order appears under the OIP ORDR form type and lives in a different dataset. A given underlying application thus produces one OIP NTC record at the notice stage and one OIP ORDR record at the order stage.

Structural stability over time

The dataset spans April 2009 to present. Across that span the OIP NTC framework is remarkably stable, and the anatomy described above applies essentially uniformly:

  • The labelled front-matter paragraphs (Agency, Action, Applicants, Summary of Application, Filing Date, Hearing or Notification of Hearing, Addresses, For Further Information Contact, Supplementary Information) and the four-part Roman-numbered body (I. Applicants' Representations, II. Applicants' Legal Analysis, III. Conditions, IV. Conclusion) are formulaic Commission-staff conventions that pre-date the EDGAR notice publication era and persist throughout the dataset.
  • Citations to Section 26(c) for substitution relief and to Section 6(c) for exemptive relief, together with Rule 22c-1, are likewise stable across the record range.
  • The Investment Company Act file-number convention 812-XXXXX, the Investment Company Act release-number convention IC-XXXXX, and the Division of Investment Management delegated-authority signature line have been continuous throughout.

The Commission has not transitioned this form type to HTML or to inline XBRL; OIP NTC notices remain published as PDF documents lodged under the SEC's own filer CIK throughout the dataset's range. Variations across records are therefore primarily editorial — the number of applicants, the number of separate accounts implicated, and the precise statutory citations vary with the relief sought, but the section grammar of the notice does not.

Interpretation and extraction notes

  • Identify the substantive document by type, not by filename. The primary PDF is frequently the EDGAR placeholder filename1.pdf. Use documentFormatFiles[0].documentUrl and type === "OIP NTC" to locate the notice; do not pattern-match on filename.
  • Distinguish the SEC filer CIK from the applicant CIK. The accession-number prefix is the SEC's internal 9999999997 filer CIK because the Commission issues the notice. The substantive applicant identity lives in entities[*].cik and is the relevant CIK for joining to insurance-company or separate-account records elsewhere.
  • Use the 812-XXXXX file number to link notice and order. A successfully prosecuted application produces both an OIP NTC notice (this dataset) and a later OIP ORDR order in a separate dataset. The two are reliably linked through the 812-XXXXX Investment Company Act file number, which is stable across the application lifecycle. Accession numbers are not.
  • Numerics are strings. size, filmNo, fiscalYearEnd, and cik are stored as strings (with zero-padding and MMDD formatting where applicable). Cast deliberately when joining to numeric data.
  • Whitespace placeholders in documentFormatFiles. The trailing complete-submission entry uses single-space sentinel values for sequence and type. Iteration code should treat single-space strings as absent values.
  • Empty structures are informative, not missing. Empty linkToXbrl, seriesAndClassesContractsInformation, and dataFiles are characteristic of the form type and reflect the genuine absence of XBRL, series/class registration data, and ancillary data files.
  • One notice can cover multiple applicants and multiple separate accounts. Read the full entities array and the Applicants paragraph of the notice rather than only the first entity when reasoning about scope.
  • The notice is a staff summary, not the full application. Specific facts — fund expense ratios, contract design details, the exact mechanics and timing of any substitution — are summarised in the notice but stated authoritatively only in the underlying Form 40-OIP application, which is a separate filing not bundled in this dataset.
  • Cross-references inside the notice. The Roman-numbered sections refer to one another by paragraph number (e.g. "see paragraph II.3 above"); preserve paragraph numbering when extracting prose so the cross-references remain resolvable.

Who Files or Publishes This Dataset, and When

Who actually files and publishes the record

Form OIP NTC is published by the U.S. Securities and Exchange Commission, not by a private registrant. On EDGAR each notice appears under a Commission-controlled administrative CIK in the 9999999997-prefix range, because the document itself is an SEC release announcing Commission action — specifically, a Notice of Application issued under the Investment Company Act of 1940.

The substantive party behind the notice is the applicant whose request the SEC is announcing. That applicant is identified inside the body of the notice (and by the docketed 812-XXXXX file number), not in the EDGAR filer field. Typical applicants are:

  • A U.S. life insurance company that issues variable annuity or variable life insurance contracts.
  • One or more registered separate accounts of that insurer, each registered with the Commission as a unit investment trust or management investment company under the 1940 Act.
  • The principal underwriter or distributor of the contracts, where required to be named.
  • An affiliated registered investment company (an underlying fund whose shares are held by the separate account) where the relief implicates affiliated-transaction provisions.

Joint applications are common: a single OIP NTC frequently names several affiliated insurers and a slate of their separate accounts as co-applicants under one IC-XXXXX release number.

What triggers the record

OIP NTC is event-driven, not periodic. The trigger sequence is:

  1. The applicant files an application on Form 40-OIP (with 40-OIP/A amendments as needed) seeking an order under the 1940 Act. The application is docketed in the Commission's 812-XXXXX file-number space, which the SEC reserves for applications for orders under the Investment Company Act.
  2. The Division of Investment Management staff reviews the application, issues comments, and works the file until the request is in substantially final form. This interval is unfixed and commonly runs from several weeks to several months.
  3. The Commission issues the OIP NTC — a Notice of Application carrying its own IC-XXXXX release number — stating the relief requested and opening the statutorily required notice-and-comment period.
  4. The notice fixes a deadline (typically about 25 days from issuance, but stated in each notice) for interested persons to request a hearing or submit comments.
  5. If no hearing is ordered, the Commission later issues an order, designated on EDGAR as OIP ORDR, with its own IC- release number cross-referencing the notice. The OIP ORDR is a separate filing type outside this dataset.

The relief sought almost always falls within one or more of:

  • Section 26(c) — Commission approval of a substitution of securities held by a registered separate account (the dominant trigger; the insurer is replacing one underlying fund inside a variable-contract separate account with another).
  • Section 17(b) — exemption from Section 17(a)'s prohibition on affiliated transactions, typically because an in-kind transfer of portfolio securities incident to the substitution would otherwise be a prohibited affiliated transaction.
  • Section 17(d) and Rule 17d-1 — relief from joint-transaction restrictions where affiliated funds or accounts are jointly affected.
  • Section 6(c) — the Commission's general authority to exempt persons or transactions from any provision of the Act when consistent with investor protection and the purposes of the Act.
  • Rule 22c-1 — relief touching forward-pricing mechanics implicated by an in-kind substitution.

Important distinctions

  • Filer vs. applicant. The EDGAR filer is the SEC's administrative CIK; the applicants are named only in the document body and identified by the 812- file number. Any analysis keyed on EDGAR filer metadata will misidentify the substantive party.
  • OIP NTC vs. 40-OIP vs. OIP ORDR. The 40-OIP (and Form 40-OIP/A) is the applicant-side filing; OIP NTC is the Commission's published notice; OIP ORDR is the eventual Commission order. A full matter spans all three, but this dataset isolates the notice stage. A 40-OIP/A amendment generally does not generate an additional OIP NTC; one notice issues once the application is sufficiently developed.
  • OIP NTC vs. APP NTC and other 1940-Act notices. The OIP track on EDGAR is specific to applications for orders under the Investment Company Act processed via the 812- docket. Notices tied to Form 40-APP, deregistration applications, or fund-merger applications travel under different form codes.
  • Reporting population. The dataset is dominated by U.S. life insurance companies and their registered separate accounts pursuing Section 26(c) substitutions. Operating companies, standalone broker-dealers, mutual fund complexes without separate-account substitutions, business development companies, and foreign private issuers do not generate OIP NTC records in the ordinary course. Routine portfolio changes or contract-form amendments that do not require a Commission order are not captured.

How This Dataset Differs From Similar Datasets or Filings

Form OIP NTC sits at one rung of a fixed Investment Company Act of 1940 procedural ladder: an applicant files a Section 26(c) substitution application on Form 40-OIP, the SEC issues a public notice (OIP NTC), the comment and hearing-request window runs, and the SEC closes the matter with an order (OIP ORDR). The closest comparison datasets are the other rungs of this ladder, the parallel APP track for non-26(c) exemptive applications, and a small set of registration and periodic-reporting forms that touch fund-substitution subject matter from a different angle.

Form 40-OIP (the underlying application)

Filer: insurance company and its registered separate accounts. Stage: opening filing. Authority: Section 26(c) of the 1940 Act. File number: 812-XXXXX. Release number: none (not a Commission release).

40-OIP carries the substantive case (factual background, contracts and funds affected, rationale, policyholder protections, requested relief). OIP NTC is the SEC-authored procedural summary of that same case. Use 40-OIP for the application text; use OIP NTC for the comment-window timestamp and Commission release identifiers.

Form 40-OIP/A (amendment)

Same filer, file number, and authority as 40-OIP. Stage: pre-notice iteration in response to staff review. Applicant-driven and may iterate multiple times; OIP NTC is issued once by the SEC after staff clears the application for public notice. A 40-OIP/A appearing after the OIP NTC signals reopened review.

OIP ORDR (the companion order)

The closest dataset to OIP NTC. Same author (SEC), same statutory hook (Section 26(c)), same file-number space (812-XXXXX), same release-number prefix (IC-XXXXX). The only material difference is procedural stage: OIP NTC opens the comment and hearing-request window; OIP ORDR closes it and constitutes the operative grant of relief. The two are typically separated by 25 to 40 days. Use OIP ORDR for the effective date of relief; use OIP NTC for the public-notice gate.

Parallel 1940 Act exemptive track

APP NTC and APP ORDR

Filer/author: SEC. Authority: 1940 Act Sections 6(c), 17, 22(c)-1, and other exemptive sections, but not 26(c). File number: 812-XXXXX. Release number: IC-XXXXX. Procedural mechanics are identical to the OIP pair.

The boundary is statutory subject matter. OIP NTC is the dedicated channel for insurance-product fund substitutions under Section 26(c); APP NTC handles all other 1940 Act exemptive relief (ETF relief, fund-of-funds, joint transactions, manager-of-managers). Applicant populations differ: insurance separate accounts dominate the OIP track; fund complexes and advisers dominate the APP ORDR track.

Form 40-APP and 40-APP/A

40-APP is to APP NTC what 40-OIP is to OIP NTC: the applicant-prepared underlying application (and its amendment) for non-26(c) exemptive matters. Same 812-XXXXX file-number space, no release number. Use 40-APP for substantive non-substitution application text; use 40-OIP for substitution application text; use OIP NTC only for the SEC's procedural notice.

Adjacent fund disclosure forms

N-CSR, N-PORT, and the rescinded N-Q

Filer: registered investment company. Authority: 1940 Act periodic-reporting rules, not exemptive. File-number space: investment company registrant files (811-XXXXX), not 812-XXXXX. No IC release number.

These are recurring, fund-authored disclosures of holdings, financial statements, and performance. Form N-CSR is event-driven, SEC-authored, and exists only while a Section 26(c) application is pending. They share nothing beyond a registered-fund nexus. They can show post-substitution holdings of separate accounts but will not reveal a proposed substitution.

Form N-14 (fund reorganization registration)

Filer: surviving registered fund. Authority: Securities Act registration plus 1940 Act, with proxy rules. File-number space: 333-XXXXX or 002-XXXXX. No IC release number.

Form N-14 is the closest non-OIP form by economic effect: both can change the fund a contractholder ultimately holds. The mechanics differ sharply. N-14 effects a fund-level merger or reorganization, requires a shareholder vote, and produces a combined prospectus/proxy. OIP NTC notices an insurer-driven substitution of one underlying fund option for another inside variable contracts, typically without contractholder vote, on the strength of an SEC exemptive order. An underlying-fund merger that incidentally affects a variable-contract menu surfaces as N-14; an insurer-initiated swap surfaces in the OIP track.

Boundary summary

OIP NTC is fixed by four converging attributes:

  • Author: SEC (not applicant)
  • Stage: notice (between application and order)
  • Statutory authority: Section 26(c) of the 1940 Act (not Sections 6(c), 17, 22(c)-1, or registration/proxy rules)
  • File-number space: 812-XXXXX; release-number prefix: IC-XXXXX

Strip any one attribute and a different dataset is correct: 40-OIP/40-OIP/A for applicant substance, OIP ORDR for the operative grant, APP NTC/ORDR and 40-APP/40-APP/A for non-26(c) exemptive matters, and N-14 or N-CSR/N-PORT for registration and periodic disclosure. OIP NTC's distinct value is mapping the public-comment gate for variable-insurance fund substitutions, with the precise IC-XXXXX release, 812-XXXXX file number, and applicant and separate-account identifiers needed to link to the rest of the application sequence.

Who Uses This Dataset

The Form OIP NTC corpus is small but precedent-dense, and a narrow set of professions rely on its structured fields: release number, 812- file number, applicants list, separate accounts, Summary of Application, Conditions, and the comment/hearing window.

1940-Act exemptive-application counsel

Outside counsel drafting Section 6(c), 17(b), and 26(c) applications use the corpus as a precedent library. They lift the Conditions section verbatim to mirror language the staff has recently accepted, align their Summary of Application with conventional phrasing, and pair the 812- file number with the originating 40-OIP and subsequent OIP ORDR to confirm the issued order tracked the noticed terms. Release numbers and notice dates feed timeline estimates in client memos.

In-house insurance securities counsel

Product and securities counsel at carriers sponsoring variable-annuity and variable-life separate accounts watch the applicants list and separate accounts to see which competitors are substituting and which fund families are moving in or out. The Summary of Application reveals the rationale (cost reduction, post-merger consolidation, performance, manager change), and the Conditions (expense caps, replacement-fund expense parity, contractholder notice periods, free-transfer rights) set the bar their own filings must meet.

Product-development and fund-substitution teams

Substitution working groups inside carriers use the dataset operationally. They benchmark scope through applicants and separate accounts, validate replaced/replacement fund pairings against the Summary of Application, and use the gap between notice date and order date (via OIP ORDR) to forecast clearance timing for substitution Gantt charts and steering-committee materials.

Paralegals and compliance staff at registrants

Docket teams at applicant insurers calendar the comment-window deadline and any hearing-request procedure, and use the release number and 812- file number as canonical IDs linking the 40-OIP, OIP NTC, and OIP ORDR in internal tracking systems. Output is a closeout memo confirming the order issued on noticed terms.

Plaintiffs' counsel in variable-product disputes

Class-action firms litigating variable-contract claims monitor notices for the applicants, separate accounts, and the Conditions and representations in the Summary of Application (expense comparisons, contractholder protections). When a later dispute arises, the noticed conditions become evidentiary material on whether the carrier honored the terms of relief.

Fund administrators and transfer agents

Operations teams that execute the substitution treat the notice as a runbook preview. They extract the replaced and replacement funds, affected separate accounts, and Conditions governing recordkeeping, free transfers, expense reimbursement, and contractholder notice timing, then translate them into NAV cut-over plans and sub-account mapping tables that go live on the order date.

State insurance regulators

Variable-product analysts at state insurance departments use the applicants and separate accounts to flag domiciled insurers seeking federal relief that touches in-state contractholders, the Summary of Application for commercial rationale, and the Conditions to judge whether contractholder protections warrant state-level follow-up.

Trade-press reporters covering insurance and asset management

Reporters at insurance and asset-management trade outlets mine the applicants and separate accounts for carrier and product names, the Summary of Application for the narrative behind a fund swap, and the comment window for stories on contractholder objection opportunities.

Academic researchers on exemptive practice

Legal and finance researchers pair notice dates with 40-OIP filing dates and OIP ORDR dates to compute review-time distributions, cluster applicants and separate accounts by carrier and fund complex, and track how Conditions language evolves across years (expense caps, notice requirements, replacement-fund quality screens).

Engineering teams building SEC notice/order corpora use the metadata file for entity resolution, the document text for section-tagging models keyed to "Applicants," "Summary of Application," "Applicable Law," and "Conditions," and the release number and 812- file number as join keys to pair each OIP NTC with its OIP ORDR for condition-carryover detection and notice-to-order matching.

Across these roles, the load-bearing fields are consistent: applicants, separate accounts, 812- file number, release number, Summary of Application, Conditions, and the comment/hearing window. Counsel and product teams use them for drafting and planning, compliance and operations teams for docketing and execution, regulators and litigators for oversight, and researchers and ML teams for structured analysis.

Specific Use Cases

The use cases below tie directly to the structured fields and PDF sections that the dataset exposes: 812-XXXXX file number, IC-XXXXX release number, applicants and separate accounts, Summary of Application, Conditions, and the hearing-request deadline.

Section 26(c) condition-template extraction for application drafting

Outside counsel drafting a new substitution application pull the numbered paragraphs from the III. Conditions section across the corpus, group them by topic (fee caps for a stated post-substitution period, free contract-owner transfers, expense reimbursement, prospectus delivery, manager-of-managers carve-outs), and assemble a clause library keyed to the IC-XXXXX release. The drafter then mirrors language the staff has recently accepted in the closest factual analogues, citing the corresponding 812-XXXXX precedents in the cover memo.

Precedent search across 812-XXXXX dockets by relief pattern

Counsel running a fact-pattern search (for example, replacement triggered by an underlying-fund merger, consolidation of a closed separate account, or substitution into an affiliated replacement fund) filter records by phrases inside I. Applicants' Representations and II. Applicants' Legal Analysis, then output a ranked list of 812-XXXXX dockets with their release numbers, applicants, and replaced/replacement fund pairs. The result is a precedent table for client memos and pre-filing staff calls.

Notice-to-order pairing dataset and review-time analytics

Engineering teams join each OIP NTC record to its companion OIP ORDR record on the 812-XXXXX file number from the entities block, producing a notice-order pair table with filedAt notice timestamp, order date, IC release numbers for both stages, and applicant CIKs. The pair table feeds review-time distributions (typically 25 to 40 days), condition-carryover detection (do order conditions match noticed conditions verbatim?), and abandonment screens (notices with no matching order within a cutoff).

Comment-window and hearing-request deadline calendaring

Paralegals and docket teams at applicant insurers parse the Hearing or Notification of Hearing paragraph for the dated, time-stamped (commonly 5:30 p.m. Eastern) deadline, combine it with the EDGAR filedAt acceptance timestamp, and write rows into an internal docketing system keyed to the 812-XXXXX file number. The output is a calendar of comment-window expiries that triggers closeout-memo workflows once the OIP ORDR posts.

Insurance-product fund-substitution monitoring

Competitive-intelligence and product-development teams at carriers run a recurring scan of the entities array for peer insurance companies and separate-account names, extract the replaced and replacement portfolios from the Summary of Application, and tag the stated rationale (cost, post-merger consolidation, manager change, performance). The output is a fund-substitution tracker showing which fund families are gaining or losing variable-contract sub-account shelf space and at which carriers.

Substitution operations runbook extraction

Fund administrators and transfer agents executing a substitution lift the Conditions paragraphs governing free transfers, expense reimbursement, recordkeeping, and contract-owner notice timing, and pair them with the affected separate accounts named in entities. These feed NAV cut-over plans, sub-account mapping tables, and contractholder-notice schedules that go live on the order date carried by the matched OIP ORDR.

Legal-analytics teams building Commission-issued notice/order models use the stable label grammar of the OIP NTC PDF (Agency, Action, Applicants, Summary of Application, Filing Date, Hearing or Notification of Hearing, Addresses, For Further Information Contact, Supplementary Information, then Roman-numbered I through IV) as a high-precision section-tagging benchmark. The 812-XXXXX file number and IC-XXXXX release number serve as join keys to pair each notice with its order for cross-document condition alignment tasks.

Dataset Access

The Form OIP NTC Files Dataset is available through three access methods: a JSON metadata index, a single archive download for the full dataset, and direct downloads of individual monthly container files. Containers cover filings from April 2009 onward and are organized by month, with each container holding YYYY-MM/<accession>/metadata.json alongside the associated PDF documents.

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

This endpoint returns dataset-level metadata (name, description, last updated timestamp, earliest sample date, total records, total size, form types covered, container format, and file types) along with the full list of monthly container files. Each container entry includes its object key, byte size, record count, last updated timestamp, and a direct download URL. The endpoint does not require an API key and can be polled to detect which containers were modified during the most recent refresh, so only changed containers need to be re-downloaded.

Example response:

Example
1 {
2 "datasetId": "1f13365b-9ae0-6a06-a048-acdf1a73ca2f",
3 "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-oip-ntc-files.zip",
4 "name": "Form OIP NTC Files Dataset",
5 "updatedAt": "2026-04-15T18:22:12.779Z",
6 "earliestSampleDate": "2009-04-01",
7 "totalRecords": 54,
8 "totalSize": 10517866,
9 "formTypes": ["OIP NTC"],
10 "containerFormat": "ZIP",
11 "fileTypes": ["PDF", "JSON"],
12 "containers": [
13 {
14 "downloadUrl": "https://api.sec-api.io/datasets/form-oip-ntc-files/2017/2017-01.zip",
15 "key": "2017/2017-01.zip",
16 "size": 412883,
17 "records": 2,
18 "updatedAt": "2026-04-15T18:22:12.779Z"
19 }
20 ]
21 }

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

Downloads the full archive containing every monthly container in a single ZIP file. This endpoint requires authentication via an API key, which can be supplied as the token query parameter or as an Authorization header.

Download Single Container: https://api.sec-api.io/datasets/form-oip-ntc-files/2017/2017-01.zip?token=YOUR_API_KEY

Downloads one monthly container ZIP using the key returned by the index API, which is useful when only a specific period is needed or when fetching only containers that changed in the latest refresh. This endpoint also requires an API key, passed via the token query parameter or Authorization header. Each container expands to a YYYY-MM/<accession>/ directory containing metadata.json and the original PDF documents for that filing.

Frequently Asked Questions

What form does this dataset cover?

The dataset covers EDGAR form type OIP NTC — Notices of Application that the SEC issues when an applicant has filed a Form 40-OIP application under the Investment Company Act of 1940. The relief is almost always an order under Section 26(c) approving a fund substitution inside an insurance-company separate account, sometimes paired with Section 6(c) exemptive relief.

What does one record in this dataset represent?

One record is a single EDGAR accession-number folder for one Notice of Application, containing a metadata.json capturing the EDGAR header and the substantive notice PDF lodged for that accession. The unit of record is the notice itself, not an applicant, a fund substitution, a separate account, or a calendar event — when a notice covers multiple applicants or substitutions, they are aggregated within that single record.

Who files or publishes Form OIP NTC?

Form OIP NTC is published by the SEC's Division of Investment Management under delegated authority, not by a private registrant, which is why each accession is lodged under the Commission's internal filer CIK 0009999999997. The substantive applicants — typically a U.S. life insurance company, one or more of its registered separate accounts, and sometimes an affiliated investment adviser, principal underwriter, or registered investment company — are named inside the body of the notice and inside the entities block of the metadata.

What time period does the dataset cover?

The dataset includes all Form OIP NTC filings submitted to EDGAR from April 2009 to the present. OIP NTC volume is low, so the monthly container calendar is sparse: months with no notices have no archive at all.

What file format is the dataset distributed in?

The dataset is distributed as monthly ZIP archives organised by year, with file types limited to PDF and JSON. Each accession folder contains a metadata.json file plus the substantive notice PDF; image files, the SGML-wrapped complete-submission .txt, HTML index renditions, and XBRL data are not bundled, although URLs back to the EDGAR-hosted versions are preserved inside metadata.json.

How does this dataset differ from the OIP ORDR dataset?

OIP NTC and OIP ORDR share the same author (SEC), the same statutory hook (Section 26(c)), the same file-number space (812-XXXXX), and the same release-number prefix (IC-XXXXX). The difference is procedural stage: OIP NTC opens the comment and hearing-request window when the application is noticed publicly, while OIP ORDR closes that window and constitutes the operative grant of relief. The two records for the same matter are typically separated by 25 to 40 days and are joined on the 812-XXXXX Investment Company Act file number.

Use the Investment Company Act file number in the 812-XXXXX series, which appears both on the notice's release line and in the fileNo field of each entities entry. That number is stable across the application lifecycle — 40-OIP application, 40-OIP/A amendments, OIP NTC notice, and OIP ORDR order — whereas EDGAR accession numbers are not. The IC-XXXXX release number can additionally be used to tie a specific notice to its companion order release.