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This is real nuisance, as noted by Jaace here:
http://forums.formtools.org/showthread.php?tid=608
Hmm... will need to rewire the code to actually upload and log the file reference despite failing validation. This will probably require a custom function in order to make it compatible with all existing validation code. Damn... Or could the ft_api_process_form function handle it somehow...? Probably not...