Privileged Relationship Exception Guide

This guide provides specific instructions for attorneys, medical professionals (including psychologists) and clergy on how to fulfill their disclosure obligations for the Current Period while maintaining professional confidentiality.

1. Understanding the Exception

   The Privileged Relationship Exception states that a Business Relationship need not be disclosed if it is a privileged relationship. This allows you to protect the identity of your clients, patients or penitents/communicants.

2. What You ARE NOT Required to Disclose

   If a University Interested Person (such as a Trustee, Officer or Key Employee) is a client or patient in your private practice, you do not need to report:

   • The name of the individual.
   • The nature of the services provided (e.g., specific legal advice, medical diagnosis or spiritual counseling).
   • The existence of the relationship as a “Business Relationship,” even if transactions exceed the $10,000 threshold.
3. What You ARE Required to Disclose

   While the specific client relationship is protected, your own professional status and business ownership are not exempt. You must still disclose the following under the definition of Material Interest:

   • Your Position: If you are an officer, director, trustee, partner, agent or employee of a law firm, medical practice, or religious organization.
   • Ownership Interest: If you own more than 5% of the professional entity (excluding passive ownership in publicly traded entities).
   • Income Thresholds: If your relationship with your own firm or practice resulted in payments of $10,000 or more in the preceding 12 months.
4. How to Complete the Form

   Instructions by Professional Role

   Professional Role	How to Handle the “Business Relationship” Section	How to Handle the “Material Interest” Section
   Attorney	If a Trustee, Officer or Key Employee is a private client, select “No” for a reportable Business Relationship based on the Exception.	List your law firm and your role (e.g., Partner). Disclose if you own >5% of the firm.
   Medical Professional	If a Trustee, Officer or Key Employee is a patient, select “No” for a reportable Business Relationship based on the Exception.	List your medical practice or clinic. Disclose any Compensation received from the practice.
   Clergy	If a Trustee, Officer or Key Employee is a congregant seeking counseling, select “No” for a reportable Business Relationship.	List the religious organization if you hold a managerial or compensated role (e.g., Priest/Pastor).

5. Important Note on “Related Entities”

   If your private practice or firm is a Related Entity (an entity 35% controlled by you and/or your Family Members), and that firm enters into a Business Transaction directly with the University (e.g., the University hires your law firm to handle a case), this must be disclosed. The exception protects private client relationships, not institutional contracts between your firm and the University.