Record Keeping

When might FOIA require the UM to provide documents related to COIs and COCs? 

Because the courts have interpreted FOIA exemptions narrowly, the University must typically disclose the types of information that are  

• strictly factual in nature (e.g., the names of the principals of an entity doing business with the University),
• otherwise publicly available from another source (e.g., stockholder disclosure forms available through the Securities and Exchange Commission website), or
• received from third parties (e.g., vendor disclosures to the University through IRS Form W-9).