The Form U-3A3-1 Files Dataset is a closed historical archive of every EDGAR submission of Form U-3A3-1, the "Twelve-Month Statement by Bank Claiming Exemption [Rule 3]" filed under the Public Utility Holding Company Act of 1935 (PUHCA 1935). Each record corresponds to a single accession-numbered submission by a bank certifying its continued eligibility for the Rule 3 (17 CFR 250.3) exemption with respect to public-utility holding company securities held in trust, custody, fiduciary, or collateral capacities. The filer in every record is the bank itself, certifying its own status for a single twelve-month reporting period. The dataset's electronic coverage begins on 1 March 1994 with the SEC's phased EDGAR rollout and ends in early 2006, when Form U-3A3-1 was discontinued upon the repeal of PUHCA 1935 by Subtitle F of Title XII of the Energy Policy Act of 2005, effective 8 February 2006. The dataset is distributed as monthly ZIP containers and bundles metadata.json together with the preserved original filing documents in TXT, JSON, and HTML formats.
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The dataset packages the complete EDGAR submission record for Form U-3A3-1, a short, tabular, self-certifying annual statement filed under Rule 3 of PUHCA 1935. Rule 3 exempted banks, broker-dealers, and certain other financial entities from being deemed holding companies for federal regulatory purposes when their relationship to public utility holding company interests was incidental to their banking, trust, or brokerage activities. To maintain that exemption, qualifying banks filed Form U-3A3-1 annually, attesting to continued eligibility and disclosing the scope of their dealings with public-utility holding company securities and obligations over the preceding twelve months.
Because Rule 3 carved out a narrow population — essentially trustee banks holding public-utility-related securities in fiduciary or collateral capacities — the form was sparingly used, and the dataset is correspondingly small and concentrated among a handful of repeat filers. The form was discontinued, not amended or superseded, when Congress repealed PUHCA 1935; no new U-3A3-1 filings were accepted after 8 February 2006. The dataset is therefore inherently closed, with a fixed date range running from March 1994 through February 2006, and is distributed as monthly ZIP containers whose contents preserve the original EDGAR submission alongside a normalized JSON header.
A record contains two clearly distinct layers: a structured metadata layer and a document layer. Physically, a record is realized as one accession-numbered folder inside a monthly ZIP container. The accession folder is named with the hyphen-stripped accession number (for example 000031524100000004 for accession 0000315241-00-000004), making each record independently addressable and self-contained.
One record in the Form U-3A3-1 Files Dataset corresponds to a single EDGAR submission of Form U-3A3-1 by a bank claiming exemption from PUHCA 1935 under Rule 3. Each record represents one bank's annual certification of continued eligibility for the Rule 3 exemption for a single twelve-month reporting period. The folder bundles a metadata.json file that captures the EDGAR submission header in structured form and the actual filing documents preserved verbatim from EDGAR, with image attachments excluded.
The filing is short and largely tabular. It is signed by a senior officer of the bank and frequently bears the bank's corporate seal. It does not include audited financial statements. The form's required content was set by Rule 3 under PUHCA 1935 and did not undergo substantive amendment over the EDGAR era; the numbered Item structure described below is stable across the dataset's full date range.
The structured layer is embodied by metadata.json, a single JSON object that mirrors and normalizes the EDGAR filing header. The fields populated for a U-3A3-1 record are:
formType — fixed as "U-3A3-1".accessionNo — the canonical hyphenated EDGAR accession number (e.g. "0000315241-00-000004").filedAt — ISO-8601 timestamp with timezone offset marking the EDGAR acceptance moment (e.g. "2000-03-31T00:00:00-05:00").description — the EDGAR human-readable description, typically "Form U-3A3-1 - Twelve-month statement by bank claiming exemption [Rule 3]".linkToFilingDetails, linkToTxt, linkToHtml — direct URLs back to the EDGAR filing folder, the complete submission text file, and the index HTML page respectively.linkToXbrl — an empty string for this dataset.documentFormatFiles — an array of descriptors for every document in the submission. Each descriptor carries sequence, size (in bytes, as a string), documentUrl, type (such as "U-3A3-1" for the form body or a blank type for the complete submission text file), and an optional description (for example "Complete submission text file").dataFiles — an empty array for this dataset; there are no structured data attachments.entities — an array of filer-entity objects describing the bank (and any jointly filing affiliates). Per-entity fields include cik (zero-padded Central Index Key, e.g. "0000315241"), companyName (suffixed (Filer) and occasionally including ET AL to indicate joint filing affiliates), type (the entity's role form type, here "U-3A3-1"), act ("35" for the 1935 Act), fileNo (the SEC file number in the 034- series characteristic of PUHCA filings, e.g. "034-00055"), filmNo (EDGAR film number), irsNo, sic (often "0000" for these bank filers), stateOfIncorporation (two-letter state code), and fiscalYearEnd as a MMDD string.id — a 32-character hex identifier that uniquely identifies the record within the dataset.The substantive content of a record is the form body itself, almost always delivered as a single plain-text document. In the dataset the document is renamed to a generic document-1.txt (with subsequent documents, when present, named document-2.*, document-3.*, and so on). The original EDGAR filename, declared type, and sequence number are preserved inside metadata.json under documentFormatFiles and can be used to reconstruct the original submission layout.
The body is a free-form filing rather than an SGML <DOCUMENT>-wrapped one, but tabular data inside the body is delimited with EDGAR's <TABLE>...<CAPTION>...<S>...<C>...</TABLE> markup so that monospaced columns render correctly. These tags are display hints for column alignment rather than parseable structured-data markup; extracting clean tabular records from these blocks requires positional parsing against the <S> and <C> column anchors rather than treating the markup as XML.
The body opens with a header naming the form, identifying the bank by name and address, stating its state of organization, and specifying the twelve-month period covered by the certification. It then proceeds through a numbered sequence of items:
(i), (ii), (iii) mapping to the holding categories).Where any item is not applicable to the bank for the period, the form states so explicitly rather than omitting the item — the numbered structure is preserved across all filings.
A representative tabular excerpt from Item 1 illustrates the column anchoring convention:
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<TABLE>
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<CAPTION>
3
____________________________________________________________________________
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<CAPTION>
5
<S> <C> <C> <C>
6
7
Name of Company Total Owned,
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and Description of Controlled or
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Securities Total Outstanding Held by Bank Nature of Holding
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(a) (b) (c) (d)
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____________________________________________________________________________
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Columbia Energy
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Group
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-common stock 84,014,000 6,749,355 (ii)
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...
17
</TABLE>
The record includes the full structured submission header in metadata.json and the full text of the Form U-3A3-1 body as filed, preserving the EDGAR table markup, the item numbering, the certification language, the signature block, and any attached schedules or appendices that were part of the original submission. For accessions whose original EDGAR submission included an HTML rendering, that HTML document is included in addition to or in place of the text document.
Image files attached to the original EDGAR submission are excluded; binary attachments such as scanned signature pages or seal images are not packaged into the record, though the textual and structured content is preserved in full. The exclusion is uniform across the dataset.
The complete submission text file (the EDGAR-generated concatenation of all components) is referenced in documentFormatFiles but its content is not bundled into the accession folder; it remains retrievable via the linkToTxt URL.
Form U-3A3-1 was filed through EDGAR over a relatively narrow window — March 1994 through early 2006 — and its presentation changed only modestly during that span. Early-period filings (1994 through approximately 2001) were typically delivered as plain ASCII text with <TABLE>-delimited tabular blocks, reflecting the prevailing EDGAR submission convention of that era. Beginning around 2002, as EDGAR began accepting HTML submissions for many form types, some U-3A3-1 filings appear in HTML form; this is why the file-types found in the dataset span TXT, JSON, and HTML even though any single record will typically carry only one body document.
Several details matter for downstream extraction and analysis.
The companyName field within entities occasionally carries the ET AL suffix (for example "MORGAN GUARANTY TRUST CO OF NEW YORK ET AL (Filer)"), signaling that the record reflects a joint filing by an affiliated group of bank entities. In such cases the disclosures within the body are aggregated across the group.
The act value "35" is the consistent indicator that a record belongs to the PUHCA 1935 regulatory regime, and the fileNo field follows the 034- prefix series the SEC used for PUHCA filings. These two fields together unambiguously distinguish U-3A3-1 records from look-alike filings under other regimes.
Document files are renamed to a generic document-N.<ext> convention; the original EDGAR filenames, declared types, and sequence numbers remain recoverable from the documentFormatFiles array.
Because the form is short, tabular, and entirely backward-looking over a fixed twelve-month period, every record is self-contained — there is no incorporation by reference to other filings, no cross-reference to financial statements, and no dependence on exhibits filed separately. Each accession folder stands alone as a complete certification record.
Each record is an annual exemption statement filed with the SEC by a bank that would, absent an available exemption, fall within the definition of a "holding company" under Section 2(a)(7) of PUHCA 1935. The filer is the bank itself, certifying its own continued eligibility. Form U-3A3-1 is not a registration statement and not a periodic operating disclosure; it is a self-certifying statement that the conditions for the Rule 3 (17 CFR 250.3) bank exemption remained satisfied during the preceding twelve months.
Eligible filers were narrow and statutorily defined:
Form U-3A3-1 was not used by public utility operating companies, by registered holding companies (which used Form U5S and the registered-system forms), or by non-bank claimants under other PUHCA exemption rules (which used Form U-3A-2 under Rule 2).
The filing was driven by a calendar-based maintenance obligation, not by a transaction or corporate event. Rule 3 conditioned continued exemption on submission of an annual statement covering the preceding twelve-month period. Accordingly, the record arises:
Each statement typically identifies the claiming bank, recites the statutory and rule basis for the exemption, describes the bank's relationship to any utility-company securities held during the period, and certifies that the Rule 3 conditions were satisfied throughout.
PUHCA 1935 required holding companies of electric and gas utilities to register with the SEC and submit to ongoing structural and transactional regulation. Section 3 authorized the Commission to exempt holding companies by rule where regulation was not necessary in the public interest. Rule 3 implemented that exemption for banks whose holding-company status was incidental to banking and trust functions; Form U-3A3-1 operationalized it as a continuing, self-certifying annual compliance obligation.
The dataset's electronic record begins on 1 March 1994, with the SEC's phased EDGAR rollout; earlier paper filings are not included. Form U-3A3-1 was discontinued when PUHCA 1935 was repealed by Subtitle F of Title XII of the Energy Policy Act of 2005, effective 8 February 2006. Authority over utility holding companies shifted to FERC under PUHCA 2005, which does not use an SEC-administered bank-exemption form. The dataset is therefore a closed corpus spanning roughly March 1994 to February 2006.
Form U-3A3-1 sits inside the bounded "U" form family created under PUHCA 1935. The only useful comparisons are other U-series forms administered by the SEC under that statute and the post-2006 FERC regime that replaced it.
The nearest sibling and the form most often confused with U-3A3-1. Both are annual exemption certifications that preserve a holding company's non-registration status, share a similar structure, and were filed up to the 2006 repeal. They differ in:
A one-time, event-driven notice filed when a company becomes a registered holding company. U-3A3-1 is the opposite posture: a recurring certification that registration is not required. A bank losing its Rule 3 exemption would exit the U-3A3-1 population and enter the Form U5A/Form U5B path. U5A is procedural; U-3A3-1 is substantive on eligibility.
The full registration statement required under Section 5 of PUHCA 1935, covering corporate structure, subsidiaries, securities, and intercompany relationships of the entire holding-company system. U5B is one-time and structural; U-3A3-1 is recurring and certificational. U5B documents companies inside the regime; U-3A3-1 documents banks staying outside it.
The annual report for already-registered holding companies and the closest cadence match to U-3A3-1. The substantive contrast is sharp: U5S is a comprehensive financial and operational report including financial statements, intercompany transactions, and service-company data, while U-3A3-1 is a brief certification of continued non-registration. U5S maps the regulated population; U-3A3-1 maps the exempt bank population.
A transactional filing used by registered holding companies to obtain SEC approval for specific acts (acquisitions, security issuances, reorganizations) under Sections 6, 7, 9, and 10. Form U-1 is transactional and approval-seeking, often producing SEC orders and amendments; U-3A3-1 is periodic, status-based, and rarely generates follow-on action. The only overlap is the shared PUHCA 1935 statutory base.
Forms such as U-9C-3, U-13-1, U-12, and U-R-1 handle specialized intra-system matters (service companies, mutual service agreements, proxy solicitations). They concern entities already inside the registered regime and are not substitutes for U-3A3-1.
The Energy Policy Act of 2005 repealed PUHCA 1935 effective February 8, 2006, and transferred residual holding-company oversight to FERC under PUHCA 2005. The entire U-form family, including U-3A3-1, ceased to be filed on EDGAR at that point. FERC's successor instruments cover related ground but differ in agency, scope, and accessibility:
These are filed with FERC rather than the SEC, are not in EDGAR, and focus on energy-sector accountability rather than the broader securities-law concerns of PUHCA 1935. The U-3A3-1 dataset is therefore inherently historical, with a fixed end date in early 2006; post-2006 exemption activity must be sourced from FERC.
Within the PUHCA 1935 family, U-3A3-1 is defined by four features taken together: annual rather than event-driven, Rule 3 (bank) rather than Rule 2 (general), certification of non-registration rather than active regulation, and a closed historical window (March 1994 to February 2006). U-3A-2 is the nearest substitute for the broader exempt population; U5S for the regulated population; U5A and U5B for the entry path into registration; U-1 for transactional activity inside the regime. None are interchangeable with U-3A3-1.
Because Form U-3A3-1 was discontinued in February 2006 with the repeal of PUHCA 1935, the dataset functions as a closed historical archive. Its users are professionals who need to reconstruct, cite, or interpret pre-2006 Rule 3 exemption claims by banks holding interests touching utility holding company structures.
Academic and policy researchers studying the dismantling of the 1935 holding company regime and the transition to the post-Energy Policy Act framework use the filings as primary sources. They focus on the stated Rule 3 exemption basis, the description of the bank's relationship to utility holding interests, and the population of filers across the 1994 to 2006 window.
Historians documenting how commercial banks, trust banks, and bank holding company affiliates interacted with investor-owned utilities consult the filings to map bank-side counterparties to utility holding arrangements. They rely on filer identity, the twelve-month certification narrative, and supporting exhibits to track which institutions repeatedly claimed Rule 3 exemption and how their disclosures evolved.
Specialist counsel advising banks on legacy PUHCA-era positions pull specific accessions when a current question turns on what a predecessor previously certified. They focus on the precise exemption language, the twelve-month certification, and descriptions of utility-related holdings, then integrate the cited filing into a regulatory memorandum or opinion.
In deals involving banks, bank holding companies, or utility-adjacent entities with long corporate histories, diligence teams use U-3A3-1 filings as SEC-filed evidence of how a target or its predecessors characterized utility holding interests. The filings corroborate or contradict management representations about pre-repeal structures and prior utility affiliations.
Forensic accountants working on legacy fiduciary disputes, trust accountings, or historical valuation matters involving utility holdings use the filings to establish what a bank represented to the SEC during specific twelve-month windows. The certification language is useful as a contemporaneous statement testable against internal records or later disclosures.
In-house counsel and compliance officers at successor entities that absorbed pre-2006 banks use the dataset as an authoritative external copy when their own records systems are incomplete. They focus on accession-level metadata and the preserved TXT and HTML submissions to support records reconstruction, litigation holds, and responses to regulator or auditor inquiries reaching into the PUHCA era.
Reference librarians and curators at law and business libraries integrate the dataset into finding aids for PUHCA-era materials. They care about completeness across the 1994 to 2006 range, accession metadata, and preservation of original document formats for patron research and digital preservation work.
Data engineers building comprehensive historical EDGAR corpora ingest the U-3A3-1 set to fill pre-2006 inventory gaps for discontinued form types. They focus on JSON metadata, accession identifiers, and filer names to support longitudinal entity resolution that links pre- and post-repeal filer identities.
Teams building retrieval-augmented systems for U.S. financial and energy regulation use the dataset to expose models to authentic PUHCA-era language, Rule 3 exemption phrasing, and mid-1990s to early-2000s SEC certification style. The TXT and HTML formats are straightforward to chunk and embed for historical question-answering and repealed-statute citation work.
The dataset is narrow and historical, but the records support several concrete workflows for PUHCA-era research, legacy diligence, and EDGAR corpus engineering.
Researchers enumerate every U-3A3-1 filer across the dataset's twelve-year window by aggregating entities.cik, companyName, and fileNo from each metadata.json. The resulting filer roster, joined to filedAt per accession, produces a year-by-year panel of which trustee banks claimed Rule 3 exemption and for how many consecutive cycles, supporting empirical work on the dismantling of PUHCA 1935.
Quant historians and forensic analysts run positional parsers against the <TABLE> / <S> / <C> column anchors in Item 1 of document-1.txt to pull out company name, security description, total outstanding, total held by the bank, and the (i)/(ii)/(iii) holding-category footnote. The output is a per-bank, per-year long-format table of utility-holding-company securities held beneficially, in fiduciary capacity, or as collateral, joinable to issuer CIKs from other EDGAR datasets.
Transactional counsel pull specific accessions for a target bank or its predecessors and cite Items 1, 5, and 6 as SEC-filed evidence of how the institution characterized utility holdings, defaulted loans, and trustee/transfer-agent fees during specific twelve-month windows. The preserved certification language and signature block from the document layer are used directly in diligence memoranda and rep-and-warranty exception schedules.
Item 3 lists officers, directors, and employees of the filing bank who simultaneously served as officers or directors of public-utility or public-utility holding companies. Parsing Item 3 across all records yields a bipartite bank-to-utility-holding-company interlock graph by year, useful for governance and corporate-network research on the late-PUHCA era.
In-house compliance teams at banks that absorbed pre-2006 trustee operations use the dataset as an external copy of record when internal archives are incomplete. The accession folder, linkToFilingDetails, and preserved TXT or HTML submission together let counsel cite the original EDGAR filing in litigation holds, regulator inquiries, and trust-accounting reconstructions reaching into the PUHCA period.
Data engineers building complete EDGAR archives ingest the dataset to close the gap left by U-3A3-1's 2006 discontinuation. The id, accessionNo, cik, and act = "35" / fileNo 034- series fields drive entity resolution that links pre-repeal U-3A3-1 filers to their post-repeal successor CIKs in other form types.
RAG and fine-tuning teams chunk the document-1.txt bodies to expose models to authentic Rule 3 exemption phrasing, twelve-month certification language, and 1990s-era EDGAR <TABLE> markup. The compact, uniform Item 1 to Item 7 structure makes the records useful as an evaluation set for repealed-statute citation, item-level extraction, and historical SEC question-answering tasks.
Dataset Index JSON API: https://api.sec-api.io/datasets/form-u3a31-files.json
The dataset index endpoint returns metadata describing the Form U-3A3-1 Files Dataset, including its name, description, last updated timestamp, earliest sample date, total record count, total size, covered form types, container format (ZIP), and content file types (TXT, JSON, HTML). The response also includes the download URL for the entire dataset and a list of individual container files, each annotated with its key, size, record count, last updated timestamp, and direct download URL. This endpoint can be polled regularly to detect which containers were modified during the most recent refresh run and to drive incremental downloads on a day-by-day basis. This endpoint does not require an API key.
Example response:
1
{
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"datasetId": "1f13365b-9ae0-6a59-a440-d6ecd67672bb",
3
"datasetDownloadUrl": "https://api.sec-api.io/datasets/form-u3a31-files.zip",
4
"name": "Form U-3A3-1 Files Dataset",
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"updatedAt": "2026-04-16T08:46:52.999Z",
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"earliestSampleDate": "1994-03-01",
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"totalRecords": 24,
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"totalSize": 127545,
9
"formTypes": ["U-3A3-1"],
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"containerFormat": "ZIP",
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"fileTypes": ["TXT", "JSON", "HTML"],
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"containers": [
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{
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"downloadUrl": "https://api.sec-api.io/datasets/form-u3a31-files/2005/2005-12.zip",
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"key": "2005/2005-12.zip",
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"size": 13818,
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"records": 3,
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"updatedAt": "2026-04-16T08:46:52.999Z"
19
}
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]
21
}
Download Entire Dataset: https://api.sec-api.io/datasets/form-u3a31-files.zip?token=YOUR_API_KEY
The full dataset is available as a single ZIP archive containing every Form U-3A3-1 filing from March 1994 through the form's discontinuation in February 2006. This endpoint requires an API key.
Download Single Container: https://api.sec-api.io/datasets/form-u3a31-files/2005/2005-12.zip?token=YOUR_API_KEY
Individual monthly container archives can be downloaded directly using the key value from the dataset index response, which is useful for retrieving only specific months without fetching the entire dataset. This endpoint requires an API key.
The dataset covers Form U-3A3-1, the "Twelve-Month Statement by Bank Claiming Exemption [Rule 3]" filed under the Public Utility Holding Company Act of 1935. It is the bank-specific annual exemption certification under Rule 3 (17 CFR 250.3) of PUHCA 1935.
One record corresponds to a single EDGAR submission of Form U-3A3-1 by one bank, certifying its continued eligibility for the Rule 3 exemption for a single twelve-month reporting period. Each record is realized as one accession-numbered folder containing a metadata.json header file and the preserved filing documents.
Filers were commercial banks, trust companies, and similar depository institutions that held voting securities of a public-utility company in a fiduciary, custodial, trust, or debt-collection capacity, and whose holding-company status under PUHCA 1935 was incidental to ordinary banking or trust activity. Public utility operating companies, registered holding companies, and non-bank exemption claimants did not file this form.
The dataset's electronic coverage runs from 1 March 1994, with the SEC's phased EDGAR rollout, through early February 2006. Form U-3A3-1 was discontinued effective 8 February 2006 when PUHCA 1935 was repealed by Subtitle F of Title XII of the Energy Policy Act of 2005, making the dataset a closed historical corpus.
Both are annual PUHCA 1935 exemption certifications, but they cite different rules and cover different filer populations. U-3A-2 is filed under Rule 2 by general holding companies (often intrastate-utility-focused), while U-3A3-1 is filed under Rule 3 specifically by banks and bank holding entities whose utility holdings arise incidentally to banking and trust activity.
Each record bundles a structured metadata.json header and the preserved filing document(s). The document layer is delivered as plain text (document-1.txt) for most filings, with HTML appearing for some submissions beginning around 2002, so the file types found in the dataset span TXT, JSON, and HTML. Image attachments from the original EDGAR submission are excluded.
The dataset is distributed as monthly ZIP containers available from the sec-api.io datasets API. A JSON index endpoint lists every container with its key, size, record count, and download URL, and both the full dataset and individual monthly containers can be downloaded directly using an API key.