Today the Government Accountability Office released a report concerning agency use of Exemption 3. GAO found that between fiscal years 2010 and 2019, 91 agencies reported withholding information using at least one of FOIA’s 256 Exemption 3 statutes a total of more than 525,000 times. Additionally,GAO found that use of Exemption 3 more than doubled from fiscal year 2012 to fiscal year 2019, while the number of FOIA requests processed increased 32 percent.