U.S. Securities and Exchange Commission 

Data Delivery Standards 

1

    Rev 02/2024 

U.S. Securities and Exchange Commission

Data Delivery Standards

This document describes the technical requirements for paper and electronic document productions to the U.S. 

Securities and Exchange Commission (SEC). **Any questions or proposed file formats other than those 

described below must be discussed with the legal and technical staff of the SEC Division of Enforcement 

prior to submission.**

General Instructions ................................................................................................................................................................................ 1 

Delivery Formats ............................................................................................................................................................ 2 

I. Imaged Productions .............................................................................................................................................................................................................................. 3 

1. Images ...................................................................................................................................................................................... 3 

2. Image Cross-Reference File .................................................................................................................................................... 3

3. Data File .................................................................................................................................................................. 3 

4. Text ..................................................................................................................................................................................... 3 

5. Linked Native Files ................................................................................................................................................................. 3 

II. Native File Productions without Load Files ............................................................................................................................. 4 

III. Adobe PDF File Productions .................................................................................................................................................. 4 

IV. Audio Files .............................................................................................................................................................................. 4 . 

V. Video Files ...................................................................................................................................................................... 4 

VI. Electronic Trade and Bank Records ......................................................................................................................................... 4 

VII. Electronic Phone Records .................................................................................................................................................... 4 

VIII. Audit Workpapers ............................................................................................................................................................. 5 

IX. Mobile Device Data ............................................................................................................................................................ 5 

General Instructions 

The current mailing address for all physical productions sent to the SEC is: 

ENF-CPU (U.S. Securities & Exchange Commission), 14420 Albemarle Point Place, Suite 102, Chantilly, VA 20151-1750

Electronic files must be produced in their native format, i.e. the format in which they are ordinarily used and maintained during the 

normal course of business. For example, an MS Excel file must be produced as an MS Excel file rather than an image of a spreadsheet. 

(Note: An Adobe PDF file is not considered a native file unless the document was initially created as a PDF.)

In the event produced files require the use of proprietary software not commonly found in the workplace, the SEC will explore 

other format options with the producing party. 

The proposed use of file de-duplication methodologies or computer-assisted review or technology-assisted review (TAR) during 

the processing of documents must be discussed with and approved by the legal and technical staff of the Division of 

Enforcement (ENF). If your production will be de-duplicated it is vital that you 1) preserve any unique metadata associated with 

the duplicate files, for example, custodian name and file location and, 2) make that unique metadata part of your production to the 

SEC. 
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General requirements for ALL document productions are: 

1. A cover letter must be included with each production and should include the following information: 

a. Case number, case name and requesting SEC staff member name 

b. A list of each piece of media included in the production with its unique production volume number 

c. A list of custodians, identifying the Bates range for each custodian 

d. A list of redacted documents and the redaction reason 

e. The time zone in which the emails were standardized during conversion 

f. Whether the production contains native files produced from Mac operating system environments 

2. Data can be produced on CD, DVD, thumb drive, etc., using the media requiring the least number of deliverables and 

labeled with the following: 

a. Case number 

b. Production date 

c. Producing party 

d. Bates range (if applicable) 

3. All submissions must be organized by custodian unless otherwise instructed. 

4. All document family groups, i.e. email attachments, embedded files, etc., should be produced together and children files 

should follow parent files sequentially in the Bates numbering. 

5. All load-ready collections should include only one data load file and one image pointer file. 

6. All load-ready text must be produced as separate document-level text files. 

7. All load-ready collections should account for custodians in the custodian field. 

8. All load-ready collections must provide the extracted contents of any container files to ensure all relevant files are produced

as separate records. 

9. Audio files should be separated from data files if both are included in the production. 

10. Only alphanumeric characters and the underscore character are permitted in file names and folder names. Special characters 

are not permitted. 

11. All electronic productions submitted on media must be produced using industry standard self-extracting encryption software. 

12. The SEC uses 7zip to access compressed files. Note that the SEC cannot accept files that use AES-256 Jpeg or pkAES-256-

Cert Deflate compression methods, even if the files are created with 7zip. If you have any questions or need additional 

information, please reach out to the requesting SEC staff member. 

13. Electronic productions of 30 GB or less are strongly encouraged to be submitted via Secure File Transfer. All Secure File 

Transfers should be sent to the SEC Centralized Production Unit (ENF-CPU@sec.gov) with a CC to the requesting SEC staff 

member. If you do not have your own Secure File Transfer application, you may reach out to the requesting SEC staff member 

for a link to the SEC system in order to upload your production. If using the SEC Secure File Transfer system, you will NOT 

be able to CC individuals outside the SEC on your upload transmission. Note that the SEC cannot accept productions made 

using file sharing sites such as Google Drive or Microsoft Office 365. 

14. Productions containing BSA or SAR material must be encrypted. Secure File Transfer applications may be used to produce 

BSA or SAR material. BSA or SAR material should be segregated and appropriately marked as BSA or SAR, or should be 

produced separately from other case related records. 

15. Passwords for electronic documents, files, compressed archives and encrypted media must be provided separately either via 

email or in a cover letter apart from the media. 

16. All electronic productions should be produced free of computer viruses. 

17. Before producing forensically collected images, parties should reach out to the requesting SEC staff member in order to 

discuss appropriate handling. 

18. Before producing unique data sets (large sets of relational data, website reconstruction, chat room data, etc.), parties should

reach out to the requesting SEC staff member in order to discuss an appropriate production format. 

19. Additional technical descriptions can be found in the addendum to this document. 

*Please note that productions sent to the SEC via United States Postal Service are subject to Mail Irradiation, and as a 

result electronic productions may be damaged.* 

 
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Delivery Formats

I. Imaged Productions

The SEC prefers that all scanned paper and electronic file collections be produced in a structured format including industry 

standard load files, Bates numbered image files, native files and searchable document-level text files. Bates numbers should not 

contain spaces. Hyphens ( - ) and underscores ( _ ) are acceptable. 

1. Images

a. Black and white images must be 300 DPI Group IV single-page TIFF files 

b. Color images must be produced in JPEG format 

c. File names cannot contain embedded spaces or special characters (including the comma) 

d. Folder names cannot contain embedded spaces or special characters (including the comma) 

e. All image files must have a unique file name, i.e. Bates number 

f. Images must be endorsed with sequential Bates numbers in the lower right corner of each image 

g. The number of image files per folder should not exceed 2,000 files 

h. Excel spreadsheets should have a placeholder image named by the Bates number of the file 

i. AUTOCAD/photograph files should be produced as a single page JPEG file 

2. Image Cross-Reference File

The image cross-reference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited 

file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the 

following format: 

ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount 

3. Data File 

The data file (.DAT) contains all of the fielded information that will be loaded into the database. 

a. The first line of the .DAT file must be a header row identifying the field names 

b. The .DAT file must use the following Concordance® default delimiters: 

Comma ASCII character (020) 

Quote þ ASCII character (254) 

c. If the .DAT file is produced in Unicode format it must contain the byte order marker 

d. Date fields should be provided in the format: mm/dd/yyyy 

e. Date and time fields must be two separate fields 

f. The time zone must be included in all time fields 

g. If the production includes imaged emails and attachments, the attachment fields must be included to preserve the 

parent/child relationship between an email and its attachments 

h. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced 

storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. 

i. For productions with native files, a LINK field must be included to provide the file path and name of the native file 

on the produced storage media. The native file must be named after the FIRSTBATES. 

j. BEGATTACH and ENDATTACH fields must be two separate fields 

 k. A complete list of metadata fields is available in Addendum A to this document 

4. Text

Text must be produced as separate document-level text files, not as fields within the .DAT file. The text files must be named 

per the FIRSTBATES/Image Key and the full path to the text file (OCRPATH) should be included in the .DAT file. Text files 

may be in either ANSI or Unicode format, however, ALL text files must be in the same format within the same production. Note 

that productions containing text with foreign characters must produce text files in Unicode format to preserve the foreign 

characters. Text files must be in a separate folder, and the number of text files per folder should not exceed 2,000 files. There 

should be no special characters (including commas) in the folder names. For redacted documents, provide the full text for 

the redacted version. 

5. Linked Native Files

Copies of original email and native file documents/attachments must be included for all electronic productions. 

a. Native file documents must be named per the FIRSTBATES number 

b. The full path of the native file must be provided in the .DAT file for the LINK field 

c. The number of native files per folder should not exceed 2,000 files 

 
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II. Native File Production without Load Files 

With prior approval, native files may be produced without load files. Native file productions should not be Bates numbered. 

Native files must be produced as they are maintained in the normal course of business and organized by custodian-named file 

folders. Native email files (.PST or .MBOX) must be separated by custodian. 

III. Adobe PDF File Production

With prior approval, Adobe PDF files may be produced in native file format. 

1. All PDFs must be unitized at the document level, i.e. each PDF must represent a discrete document. 

2. PDF files should be produced in separate folders named by the custodian. The folders should not contain any special 

characters (including commas). 

3. All PDF files must contain embedded text that includes all discernible words within the document, not selected text 

or image only. This requires all layers of the PDF to be flattened first. 

4. If PDF files are Bates endorsed, the PDF files must be named by the Bates range. 

IV. Audio Files

Audio files from telephone recording systems must be produced in a format that is playable using Microsoft Windows 

Media PlayerTM. Additionally, the call information (metadata) related to each audio recording MUST be provided. The 

metadata file must be produced in a delimited text format. Field names must be included in the first row of the text file. 

The metadata must include, at a minimum, the following fields: 

 1) Caller Name: Caller’s name or account/identification number 

 2) Originating Number: Caller’s phone number 

 3) Called Party Name: Called party’s name 

 4) Terminating Number: Called party’s phone number 

 5) Date: Date of call 

 6) Time: Time of call 

 7) Filename: Filename of audio file 

V. Video Files

Video files must be produced in a format that is playable using Microsoft Windows Media PlayerTM. 

VI. Electronic Trade and Bank Records

When producing electronic trade records, bank records, or financial statements, provide the files in one of the following formats: 

1. MS Excel spreadsheet with header information detailing the field structure. If any special codes exist in the dataset, a 

separate document must be provided that details all such codes. If details of the field structure do not fit in the header, a 

separate document must be provided that includes such details. 

2. Delimited text file with header information detailing the field structure. The preferred delimiter is a vertical bar “|”. If

any special codes exist in the dataset, a separate document must be provided that details all such codes. If details of the

field structure do not fit in the header, a separate document must be provided that includes such details. 

VII. Electronic Phone Records 

When producing an MS Excel spreadsheet for electronic phone records, provide the files in the following format: 

1. MS Excel spreadsheet with header information detailing the field structure. If any special codes exist in the dataset, a 

separate document must be provided that details all such codes. If details of the field structure do not fit in the header, a 

separate document must be provided that includes such details. Data must be formatted in its native format (i.e. 

dates in a date format, numbers in an appropriate numerical format, and numbers with leading zeroes as text). 

a. The metadata that must be included is outlined in Addendum B of this document. Each field of data must be 

loaded into a separate column. For example, Date and Start_Time must be produced in separate columns and 

not combined into a single column containing both pieces of information. Any fields of data that are provided 

in addition to those listed in Addendum B must also be loaded into separate columns. 

 
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VIII. Audit Workpapers 

The SEC prefers for workpapers to be produced in two formats: (1) With Bates numbers in accordance with the SEC Data 

Delivery Standards; and (2) in native format via laptop computer, web-based viewing platform, or otherwise, allowing for 

viewing in the same format and organization as the firm’s audit team. Prior to production of workpapers via laptop computer 

or web-based viewing platform, audit firms should contact the requesting SEC staff member for additional information and 

written agreements addressing use of software, access, and viewing protocols. 

IX. Mobile Device Data 

Before producing any mobile device data (including but not limited to text messages and application data) parties should 

reach out to the requesting SEC staff member in order to discuss the appropriate production format. Productions containing 

chat data from applications must be identified at the time of production and the following information must be provided to 

the requesting SEC staff member and the SEC Centralized Production Unit: chat application, chat data format, and how the 

length of a chat is determined (i.e. set duration of time, number of minutes without messages, etc.) 
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ADDENDUM A 

The metadata of electronic document collections should be extracted and provided in a .DAT file using the field definition and 

formatting described below: 

Field Name Sample Data Description

FIRSTBATES EDC0000001 First Bates number of native file document/email

LASTBATES EDC0000001 Last Bates number of native file document/email 

**The LASTBATES field should be populated 

for single page documents/emails.

ATTACHRANGE EDC0000001 - EDC0000015 Bates number of the first page of the parent

document to the Bates number of the last page of the 

last attachment “child” document

BEGATTACH EDC0000001 First Bates number of attachment range

ENDATTACH EDC0000015 Last Bates number of attachment range

PARENT_BATES EDC0000001 First Bates number of parent document/Email 

**This PARENT_BATES field should be populated 

in each record representing an attachment “child” 

document

CHILD_BATES EDC0000002; EDC0000014 First Bates number of “child” attachment(s); can be 

more than one Bates number listed depending on the 

number of attachments 

**The CHILD_BATES field should be populated in 

each record representing a “parent” document

CUSTODIAN Smith, John Email: Mailbox where the email resided 

Native: Name of the individual or department from

whose files the document originated

FROM John Smith Email: Sender

Native: Author(s) of document 

**semi-colon should be used to separate multiple 

entries

TO Coffman, Janice; LeeW 

[mailto:LeeW@MSN.com]

Recipient(s) 

**semi-colon should be used to separate multiple 

entries

CC Frank Thompson [mailto: 

frank_Thompson@cdt.com]

Carbon copy recipient(s) 

**semi-colon should be used to separate multiple 

entries

BCC John Cain Blind carbon copy recipient(s) 

**semi-colon should be used to separate multiple 

entries

SUBJECT Board Meeting Minutes Email: Subject line of the email 

Native: Title of document (if available)

FILE_NAME BoardMeetingMinutes.docx Native: Name of the original native file, including

extension 

DATE_SENT 10/12/2010 Email: Date the email was sent

Native: (empty)

TIME_SENT/TIME

_ZONE

07:05 PM GMT Email: Time the email was sent/ Time zone in which

the emails were standardized during conversion. 

Native: (empty) 

**This data must be a separate field and cannot be 

combined with the DATE_SENT field 

TIME_ZONE GMT The time zone in which the emails were standardized

during conversion. 

Email: Time zone 

Native: (empty) 
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LINK D:\001\ EDC0000001.msg Hyperlink to the email or native file document

**The linked file must be named per the 

FIRSTBATES number

MIME_TYPE application/msword The content type of an email or native file document

as identified/extracted from the header

FILE_EXTEN MSG The file type extension representing the email or

native file document; will vary depending on the 

format

AUTHOR John Smith Email: (empty) 

Native: Author of the document

LAST_AUTHOR Jane Doe Email: (empty) 

Native: Last Author of the document 

DATE_CREATED 10/10/2010 Email: (empty) 

Native: Date the document was created

TIME_CREATED/T

IME_ZONE

10:25 AM GMT Email: (empty) 

Native: Time the document was created including time

zone 

**This data must be a separate field and cannot be 

combined with the DATE_CREATED field

DATE_MOD 10/12/2010 Email: (empty) 

Native: Date the document was last modified

TIME_MOD/TIME_

ZONE

07:00 PM GMT Email: (empty) 

Native: Time the document was last modified including

the time zone 

**This data must be a separate field and cannot be 

combined with the DATE_MOD field

DATE_ACCESSD 10/12/2010 Email: (empty) 

Native: Date the document was last accessed

TIME_ACCESSD/T

IME_ZONE

07:00 PM GMT Email: (empty) 

Native: Time the document was last accessed including

the time zone 

**This data must be a separate field and cannot be 

combined with the DATE_ACCESSD field

PRINTED_DATE 10/12/2010 Email: (empty) 

Native: Date the document was last printed

FILE_SIZE 5,952 Size of native file document/email in KB

PGCOUNT 1 Number of pages in native file document/email

PATH J:\Shared\SmithJ\October

Agenda.doc

Email: (empty) 

Native: Path where native file document was stored 

including original file name.

INTFILEPATH Personal Folders\Deleted

Items\Board Meeting 

Minutes.msg

Email: original location of email including original

file name. 

Native: (empty)

INTMSGID <000805c2c71b$75977050$cb

8306d1@MSN>

Email: Unique Message ID 

Native: (empty)
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HEADER Return-Path: 

<example_from@dc.edu> 

X-SpamCatcher-Score:1[X] 

Received:from[136.167.40.119]

(HELO dc.edu) 

by fe3.dc.edu (CommuniGate

Pro SMTP4.1.8) 

with ESMTP-TLS id 61258719

for example_to@mail.dc.edu; 

Mon, 23 Aug 2004 11:40:10 -

0400 

Message-ID: 

<4129F3CA.2020509@dc.edu>

Date: Mon, 23 Aug 2005

11:40:36 -400 

From: Taylor Evans

<example_from@dc.edu> 

User-Agent:Mozilla/5.0 

(Windows;U; Windows NT 5.1;

en-US;rv:1.0.1) 

Gecko/20020823 Netscape/7.0 

X-Accept-Language:en-us,en 

MIME-Version:1.0 

To: Jon Smith

<example_to@mail.dc.edu> 

Subject:Business Development

Meeting 

Content-Type: 

text/plain;charset=us-ascii; 

format=flowed 

Content-Transfer-Encoding:7bit

Email: The email header information 

Native: (empty) 

SHA256 AD6128C5CA40164AF71A1E

FC800E12D2F195CE07BB5F8

C813B0888A2DDE6A06F

SHA-256 hash value of the document.

OCRPATH TEXT/001/EDC0000001.txt Path to extracted text of the native file 

Sample Image Cross-Reference File: 

IMG0000001,,E:\001\IMG0000001.TIF,Y,,,

IMG0000002,,E:\001\IMG0000002.TIF,,,,

IMG0000003,,E:\001\IMG0000003.TIF,,,,

IMG0000004,,E:\001\IMG0000004.TIF,Y,,,

IMG0000005,,E:\001\IMG0000005.TIF,Y,,,

IMG0000006,,E:\001\IMG0000006.TIF,,,,

   
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ADDENDUM B 

For Electronic Phone Records, include the following fields in separate columns: 

For Calls: 

1) Account Number 

2) Connection Date – Date the call was received or made 

3) Connection Time – Time call was received or made 

4) Seizure Time – Time it took for the call to be placed in seconds 

5) Originating Number – Phone that placed the call 

6) Terminating Number – Phone that received the call 

7) Elapsed Time – The length of time the call lasted, preferably in seconds 

8) End Time – The time the call ended 

9) Number Dialed – Actual number dialed 

10) IMEI Originating – Unique id to phone used to make call 

11) IMEI Terminating– Unique id to phone used to receive call 

12) IMSI Originating – Unique id to phone used to make call 

13) IMSI Terminating- Unique id to phone used to receive call 

14) Call Codes – Identify call direction or other routing information 

15) Time Zone – Time Zone in which the call was received or placed, if applicable 

For Text messages: 

1) Account Number 

2) Connection Date – Date the text was received or made 

3) Connection Time – Time text was received or made 

4) Originating Number – Who placed the text 

5) Terminating Number – Who received the text 

6) IMEI Originating – Unique id to phone used to make text 

7) IMEI Terminating– Unique id to phone used to receive text 

8) IMSI Originating - Unique id to phone used to make text 

9) IMSI Terminating- Unique id to phone used to receive text 

10) Text Code – Identify text direction, or other text routing information 

11) Text Type Code – Type of text message (sent SMS, MMS, or other) 

12) Time Zone – Time Zone in which the call was received or placed, if applicable 

For Mobile Data Usage: 

1) Account Number 

2) Connection Date – Date the data was received or made 

3) Connection Time – Time data was received or made 

4) Originating number – Number that used data 

5) IMEI Originating – Unique id of phone that used data 

6) IMSI Originating - Unique id of phone that used data 

7) Data or Data codes – Identify data direction, or other data routing information 

8) Time Zone – Time Zone in which the call was received or placed, if applicable