7(1)(t)

How the Public Access Counselor has treated 7(1)(t)

Section 7(1)(t) is labeled here as the exemption for financial institution and insurer regulatory examination reports. In the decisions provided, public bodies also invoked it for other types of evaluative records, including a consultant's review of university athletics operations described as an internal audit or management review, police records about a death investigation, a school board email attachment, and materials from a professional disciplinary case file.

The PAC has upheld withholding in some cases and rejected it in others. It agreed that Southern Illinois University could withhold a consultant's athletics review and that the Department of Financial and Professional Regulation could withhold remaining case file materials. By contrast, it found violations where Hinsdale Township High School District 86 withheld a board email attachment and where the Park Ridge Police Department withheld death investigation records without providing clear and convincing evidence for an applicable state exemption.

At a glance: 4 documents from 2025(1 binding opinion, 3 determination letters). Most often cited alongside: 7(1)(a) (Confidential under other federal or State law) (3); 7(1)(b) (Private information) (2); 7(1)(c) (Personal privacy) (2); 7(1)(d)(i) (Would interfere with pending/contemplated law-enforcement proceedings) (1); 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (1).

Recurring issues

• Whether a consultant's review of university athletics operations qualifies for withholding under section 7(1)(t) as an internal audit or management review. (Consultant's review of university athletics operations and contract)
• Whether an athletic director counts as the head of the public body with authority to waive the 7(1)(t) exemption. (Consultant's review of university athletics operations and contract)
• Whether a school district can rely on 7(1)(t) alongside other exemptions to withhold an email attachment sent to board members. (Email attachments between school board members)
• Whether police records about a death investigation can be withheld under 7(1)(t) without clear and convincing evidence of an applicable state exemption. (Death investigation records and police-federal communications)
• Whether remaining materials in a disciplinary case file beyond an initial order are exempt from disclosure. (Investigative materials and hearing transcripts from a 2013 disciplinary order)

Practical points

• A public body invoking 7(1)(t) should provide clear and convincing evidence that a state exemption applies rather than relying on federal FOIA exemptions.
• A waiver question about 7(1)(t) turns on action by the head of the public body, not subordinate officials.
• A requester seeking disciplinary or review records may receive only non-exempt portions, such as an initial order, if the body does not possess other materials and the remainder is exempt.

Summary drafted from the linked decisions and checked against them; read the decisions themselves before relying on it. Not legal advice.