Can Exemption 4 be invoked to protect personal financial information?
Yes. Exemption 4 protection can be extended to any privileged or confidential financial information, regardless of whether it concerns a business or an individual. This was first recognized expressly in Rural Housing Alliance v. United States Department of Agriculture, 498 F.2d 73, 78 (D.C. Cir. 1974) (personal financial information derived from loan applications), and was emphasized more recently in Washington Post Co. v. HHS, 690 F.2d 252, 266 (D.C. Cir. 1982) (personal financial data of agency consultants). Indeed, Exemption 4 should always be considered as a means of protecting personal financial information because its applicability to such data may in some instances be even greater than that of Exemption 6. See, e.g., id. at 269. Does commercial information lose its Exemption 4 protection with the passage of time? Not necessarily. Commercial information remains entitled to Exemption 4 protection so long as its disclosure would be likely to cause substantial competitive harm. For
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