CFTC Data Delivery 

Standards

Effective: January 27, 2023 

This document describes the technical requirements for electronic document productions to the 

Commodity Futures Trading Commission (CFTC). Any proposed file formats other than those described 

below must be discussed with the legal and technical staff of the CFTC Division of Enforcement prior to 

submission.
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

This document describes the technical requirements for electronic document productions to the 

Commodity Futures Trading Commission (CFTC). 

**Any proposed file formats other than those described below must be discussed with the legal and 

technical staff of the CFTC Division of Enforcement prior to submission.** 

Contents

General Instructions ........................................................................................................................ 2

Electronic Discovery Protocols ................................................................................................... 3

Delivery Formats ............................................................................................................................ 3

I. Native File Production ......................................................................................................... 3

1. Emails ........................................................................................................................... 3

2. Account Statements ...................................................................................................... 3

3. Instant Messages (IMs) ................................................................................................. 4

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

5. Video Files .................................................................................................................... 5

6. Transcripts .................................................................................................................... 5

II. Load Ready Production .................................................................................................... 5

1. Images ........................................................................................................................... 5

2. Image Load Cross-Reference File ................................................................................ 6

3. Data Load File .............................................................................................................. 7

4. Text ............................................................................................................................... 9

5. Linked Native Files .................................................................................................... 10

III. Productions of Adobe PDF Files .................................................................................... 10

IV. Productions of Website Content ..................................................................................... 10

V. Productions of Forensic Images of Computer Media ..................................................... 10

VI. Productions of Forensically Acquired Mobile Device Data .......................................... 11

VII. FTP (File Transfer Protocol) Submission ...................................................................... 11
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CFTC Data Delivery Standards 

Effective: January 27, 2023

General Instructions

Please send documents via overnight mail (1155 21st Street NW, Mailstop CPI, Washington, DC, 20581) 

or use the Commission’s secure file transfer protocol (“FTP”); do not produce any documents via the 

U.S. Postal Service. . If you are interested in sending documents using FTP, email eLaw-CPI@cftc.gov

and they will provide you with the Commission’s FTP credentials upon request. When sending 

documents via FTP, you MUST include the CFTC point of contact and a cover letter. 

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, 

please provide the CFTC a static copy of the application in order to view and process the data.

General requirements for ALL document productions are: 

1. Production of data via email is unacceptable.

2. Reference the specific portion of the request to which you are responding, along with a summary

of the number of files in the production, so that we can confirm everything is loaded into our

review system.

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

4. All load-ready productions should include only one data load file and one image pointer file.

5. All load-ready productions DAT file header should match the field names as indicated in the

Load Ready Production field chart in section II below.

6. All load-ready text must be produced as separate text files, not as fields within the .DAT file.

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

a. If using deduplication methods, provide the deduped custodians name in the Additional

Custodians field of the DAT file.

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

9. The preferred method of submission is via File Transfer Protocol (FTP). (See details in Section

IV on page 10.)

10. Large productions (any production above 10 GB) must be submitted to the CFTC on media such

as a CD, DVD, thumb drive, or hard drive. The media must be clearly marked with the following:

a. Matter name

b. Producing party

c. Production date

d. Disk number (1 of X), if applicable

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

names. Special characters are not permitted. Any data received with file names or folders with

special characters, including the comma, will be rejected. The combined length of the file path

with folder and file name should not exceed 255 characters.
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

12. Include information within the cover letter regarding the time zone used if emails or other

electronic files were standardized during conversion.

a. Load ready productions should have the time zone information in the Time Zone Field. It 

should not be part of the Date Sent or Time Sent Fields.

13. If you want the submitted material returned at the conclusion of the investigation you must 

indicate that preference in writing when the material is produced and the media on which it is 

provided must be encrypted.

14. All production data containing sensitive or personally identifiable information must be encrypted

using FIPS 140 compliant software. 

15. Provide passwords for all password-protected files or hardware in a separate transmittal.

16. All productions should be checked and produced free of computer viruses and malware. 

Productions containing viruses or malware may not be accepted and will require a new 

production.

17. If the production is created using Relativity Email Threading efforts, Duplicate Spare = No must 

not be applied.

Electronic Discovery Protocols

If a producing party wants to employ culling techniques to reduce the volume of production material, then 

consultation with the CFTC attorney is required to define and agree upon the requirements and applied 

technology. Thereafter, all productions made to the CFTC should reference the established protocol. Such 

methodologies may include, but are not limited to, the following criteria: 

• Data Sources

• Custodians 

• Date Range(s)

• Search Terms

• Deduplication

• Email Threading Usage

• Early Case Assessment (ECA) Usage

• Technology Assisted Review (TAR)

• Other Criteria, including alternative forms of analytics

Delivery Formats

I. Native File Production

Requirements for the production of native document files are listed below. 

1. Emails: Emails and attachments must be produced as PST, NSF, DBX, MBOX, or 

MSG files. The file name must include the name of the email custodian. When a 

production consists of multiple custodians, a separate PST (or similar file) should be 

produced for each custodian. 

2. Account Statements: Account statements must be produced in the same format in 

which they were originally created and distributed. 
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

3. Instant Messages (IMs): IMs should be produced in .PST format or a delimited text 

file which must include, at a minimum, the following fields: 

1) DATE

2) TIME 

3) FROM

4) TO

5) CONVERSATION_TEXT

6) CONVERSATION_INDEX

Multiple conversations must be produced in a single file and a conversation index or 

similar unique string must be used to identify all threads of the same conversation. Field 

names must be included in the first row of the text file.

4. Audio Files: Audio files from telephone recording systems must be produced in a 

format that is playable using Microsoft Windows Media PlayerTM. Types of audio files 

that will be accepted include:

Produced audio files must be in a separate folder compared to other data in the 

production.

Additionally, the call information (metadata) related to each audio recording must be 

produced if it exists. The metadata must include, at a minimum, the following fields: 

1) Caller_Name: Caller’s name or identification number

2) Calling_Number: Caller’s phone number

3) Filename: Filename of audio file

4) Call_Date: Date of call

5) Call_Time: Time of call

6) Called_Party: Name of the party called

7) Called_Number: Called party’s phone number

The filename is used to link the metadata to the produced audio file. The file name in the 

metadata and the file name used to identify the corresponding audio file must match 

exactly. The metadata file must be produced in delimited text format. Field names must 

be included in the first row of the text file. A sample .DAT file containing only a few 

fields for illustration purposes is depicted below:
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

5. Video Files: Video files must be produced in a format that is playable using Microsoft 

Windows Media PlayerTM along with any available metadata. If it is known that the video 

files do not contain associated audio, indicate this in the accompanying transmittal letter. 

Types of video files accepted include:

• MPG

• AVI

• WMV

• MOV

• FLV

• MPEG

• VOB

• QT

6. Transcripts: Legal transcripts must be produced electronically in manuscript form with 

line numbers and page numbers. The preferred format is plain text (ASCII), although 

LiveNote and Summation formats are acceptable.

II. Load Ready Production

While the CFTC accepts load ready productions in addition to native formats, imaged productions 

without native formats are not permitted unless the original document only exists in hard copy 

form. . When images are produced, they must comply with the requirements below. 

***The use of file de-duplication methodologies in preparing productions is becoming more 

commonplace. If your production will be de-duplicated it is vital that you preserve any 

unique metadata associated with the duplicate files. For example, custodian name for the 

files deduplicated out and not provided should be populated in the Additional Custodians 

field for the copy of the record that is provided.***

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

b.

1. Images 

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.

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

image.

g. The number of TIFF files per folder should not exceed 500 files.
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

h. TIFF images of Excel spreadsheets are not useful for review purposes; because the 

imaging process can often generate thousands of pages per file, a placeholder image, 

named by the IMAGEID of the file, should be used instead, and the native Excel file 

should be produced.

2. Image Load Cross-Reference File

The image cross-reference file is needed to link the images to the database. It is a commadelimited file consisting of seven fields per line. There must be a line in the cross-reference 

file for every image in the database. 

The format is as follows: 

ImageKey,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount

ImageKey: This is the unique designation that Concordance and Concordance Image 

and Relativity use to identify and retrieve an image. This value may be 

the same as the Bates number endorsed on each image.

VolumeLabel: Leave this field empty. 

ImageFilePath: This is the full path to the image file on the produced storage media.

DocumentBreak: This field is used to delineate the beginning of a new document. If this 

field contains the letter “Y,” then this is the first page of a document. If 

this field is blank, then this page is not the first page of a document.

FolderBreak: This field is used to delineate the beginning of a new folder in the same 

manner as the DocumentBreak field. If this information is not available, 

then it may be left empty.

BoxBreak: This field is used to delineate the beginning of a new box in the same 

manner as the DocumentBreak and FolderBreak fields. If this 

information is not available, then it may be left empty.

PageCount: Leave this field empty. 

Sample LA-0000001,,E:\001\ LA-0000001.TIF,Y,,,

LA-0000002,,E:\001\ LA-0000002.TIF,,,,

LA-0000003,,E:\001\ LA-0000003.TIF,Y,,,

LA-0000004,,E:\001\ LA-0000004.TIF,,,,

LA-0000005,,E:\001\ LA-0000005.TIF,,,,
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

3. Data Load File

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

into a Relativity® database. 

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

names.

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

Comma ASCII character 20

Quote þ ASCII character 254

Newline ® ASCII character 174

c. Date fields should be provided in the format: MM/DD/YYYY. 

d. 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.

e. A TEXTPATH 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 Begno. Do not include the text in the .DAT file. 

f. For production with native files, a NATIVELINK field must be included to 

provide the file path and name of the native file on the produced storage 

media.

g. BegAtt and EndAtt fields must be two separate fields.

h. DateSent and TimeSent fields must be two separate fields.

i. All text and metadata associated with the document collection must be 

produced. 

Sample of .DAT file (only includes a sample of fields) 

þBegnoþþBegAttachþþEndAttachþþFileDescripþþFilenameþþRecordTypeþ

þEML-0030437þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030438þþþþþþOutlook Data FileþþRE: Your Question.htmþþþ 

þEML-0030439þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030440þþþþþþOutlook Data FileþþLook.htmþþE-MAILþþþ 

þEML-0030441þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030442þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030443þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030444þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030445þþþþþþOutlook Data FileþþATTN.htmþþE-MAILþþþ 

þEML-0030446þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030447þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 

þEML-0030448þþþþþþOutlook Data FileþþQuestion Fill Out Form.htmþþþ 
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

The metadata for the document collection should be provided in a .DAT file using the field 

name, definition, and formatting described below: 

Field Description Field Type Required

DocBeg Displays the document identifier of the 

first page in a endorsed document or the 

entire document if provided in native.

Text Yes

DocEnd Page endorsement of the last page in a 

document (for image collections only).

Text Yes for Image 

Collections

DocBegAttach Displays the document identifier of a 

parent record. Must be separate from 

DocEndAttach field.

Text If it Exists

DocEndAttach Displays the document identifier of the 

last attached .document in a family. Must 

be separate from DocBegAttach field.

Text If it Exists

Pages Number of pages in a document (for 

image collections only).

Text Yes for Image 

Collections

File Description Description of a native file type. Text Yes

File Extension The file type extension representing the 

email or native file document.

Text Yes

Filename Original filename of a native file. Text Yes for Documents

File Type Displays the record type for each entry in 

the load file.

Text Yes

Parent Document 

ID

Displays the document identifier of the 

attachment record's parent (only for 

attachments).

Text If it Exists

Attachment Count Total number of records attached to the 

document. The value will always be 0 

(zero) for the actual attachment records.

Text If it Exists

Attachment Bates 

Number

Populates parent records with document 

identifier of each attached record and is 

separated by semi-colons.

Text If it Exists

Custodian The owner of the record. Text Yes

Additional 

Custodian

The owner of the record who was 

deduplicated. If multiple names, separate 

by semicolon.

Text If it Exsits

Email From Author of the e-mail message. Text Yes for email

Email To Main recipient(s) of the e-mail message. Text Yes for email

Email CC Recipient(s) of "Carbon Copies of the email message.Text If it Exists

Email BCC Recipient(s) of "Blind Carbon Copies" of 

the e-mail message.

Text If it Exists

Email Subject Subject of the e-mail message. Paragraph Yes for email

Date Sent Sent date of an e-mail message. Must be 

separate from TimeSent field.

MM/DD/YYYY Yes for email

Time Sent Time the e-mail message was sent. Must 

be separate from DateSent field.

Text Yes for email

Time Zone Field Indicates what time zone was used during 

processing.

Text Yes for email
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

Field Description Field Type Required

Email Message ID Internet Message ID assigned to an email message by the outgoing mail 

server.

Text If it Exists

Conversation

Index

This is a 44 character string of numbers 

and letters that is created in the initial 

email and which as 10 characters added 

for each reply or forward of an email.

Text Yes for email

Conversation 

Family

E-mail thread identification. Relational 

field for Conversion threads.

Text Yes for email

Email Entry ID Unique identifier of e-mails in mail 

stores.

Text If it Exists

Document Author Author value pulled from metadata of the 

native file.

Text If it Exists

Document 

Organization

Company extracted from metadata of the 

native file.

Text If it Exists

Document Subject Subject value extracted from metadata of 

the native file.

Paragraph If it Exists

Document Title Title value extracted from metadata of the 

native file.

Paragraph If it Exists

Date Created Creation date of the native file. MM/DD/YYYY If it Exists

Date Last

Modified

Date the native file was last modified. MM/DD/YYYY If it Exists

Date Last Printed Date the native file was last printed. MM/DD/YYYY If it Exists

MD5Hash MD5 hash value. Text Yes

Call_Date Date of call. MM/DD/YYYY For audio calls

Call_Time Time of call. Text For audio calls

Calling_Number Caller’s phone number. Text For audio calls

Caller_Name Caller’s name. Text For audio calls

Called_Number Called party’s phone number. Text For audio calls

Called_Party Name of party called. Text For audio calls

Folder Path Fully qualified original folder path to the 

source files and/or mail stores for each 

record.

Text Yes

Native File Hyperlink to the native file. Text Yes

Text Path Extracted text path. Paragraph Yes

Image Key Page ID of the first page of a document 

(for image collections only). Should be 

the same as the Begno field.

Paragraph Yes

+ Any other fields considered relevant by the producing party.

4. Text

Text must be produced as separate text files, not as fields within the .DAT file. If text is 

included in the .DAT file as a field, the production will be rejected. Extracted text must be in 

a separate folder, one text file per document. The files must be named the same as the Begno 

field. The number of files per folder should not exceed 500 files. There should be no special 

characters (including commas in the folder names).
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

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 Begno field.

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

field.

c. The number of native files per folder should not exceed 500 files.

d. There should be no special characters (including commas in the folder names).

III. Productions of Adobe PDF Files 

PDF files are not substitutions for native files, as metadata is lost when PDFing native files. 

PDF productions that are produced as native productions will be rejected unless the files were 

originally created using Adobe, contains protected information that was redacted, or prior 

agreement is reached with the designated CFTC attorney. In those exceptions, PDF productions 

should adhere to the following guidelines:

1. PDF files should be produced in separate folders named by the custodian. The folders should 

not contain any special characters (including commas).

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

document; a PDF cannot contain multiple documents. PDF packages will be rejected.

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 endorsed, the PDF files must be named by the first page of the endorsed 

document. 

a. Please provide a cross reference file that lists the DocBeg & DocEnd, of each PDF.

5. If PDF files include financial statements such as credit card statements, bank statements and 

brokerage statements, you must provide quality documents by either directly converting them 

from their original file format or by scanning them using a minimum of 600 dpi.

IV. Productions of Website Content 

Website content must be produced in native format and viewable in common web browsers (e.g. 

Internet Explorer, Mozilla Firefox, and Google Chrome) without the use of any additional third 

party software. If the only existing state of a website is in source code form, the party must 

produce a fully compiled version of the website in addition to the website source code with 

documentation of the process used to render, compile, and/or restore the website to an easily 

viewable form.

V. Productions of Forensic Images of Computer Media

Forensic images must be produced in a common/standard format to include (E01, Ex01, L01, 

Lx01, AD1, Raw Bitstream, and S01). An inventory of any original computer media must be 

provided with the image files. All associated log files from any forensic acquisition must be 

produced with the image files. The log files must contain a hash value, at a minimum (MD5, 
 

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CFTC Data Delivery Standards 

Effective: January 27, 2023

SHA-1, or higher), for authentication purposes. A chain of custody document must be provided to 

ensure the integrity of any digital evidence. 

VI. Productions of Forensically Acquired Mobile Device Data

Forensically acquired mobile device data must be provided in the original format of the 

software/hardware used to capture the data. All original logs and authentication reports must also 

be provided with the respective data.

VII. FTP (File Transfer Protocol) Submission

The preferred method for producing data is via FTP. The CFTC has an FTP site set up that will 

allow transfer of data up to 50 GB per transmission.

If you are interested in sending documents using FTP, email eLaw-CPI@cftc.gov and they will 

provide you with the Commission’s FTP credentials upon request. When sending documents via 

FTP, you MUST include the CFTC point of contact and a cover letter.