Record Keeping

When might FOIA require the U-M 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).