The COI Officer will retain all disclosures, conflict management plans, and related documents for a period of at least three years following submission of the final expenditure report for the applicable project to the sponsor of the research that gives rise to the Financial Conflict of Interest, unless any litigation, claim or negotiation, audit, or other action involving the records is commenced before expiration of the three-year period, in which case, records will be retained until completion of the action and resolution of all issues.