No it's not, well I heard a rumor circulating that Boris Voto-..something Russian, the guy who made ENB series, said the files are hard to access. That was proven false, apparently Boris (the enb dude) only said that because he was mad about his shaders not being compatible or some shit.
To put it more eloquently: Boris was pissed about his ENB shit not working well or whatever. Keep in mind, this is the same guy who thought Rockstar hated him personally because his mods weren't working with GTA IV's patch 1.0.7.0. People have already accessed the files, it's not Max Payne 3 bad.