"My first recommendation is that we communicate with Harvard's administration immediately and ask them to change their reporting methods on the PC which is now due (and not yet received)," Lund wrote in an April 26, 1991 memo to Allen. "Harvard's fiscal year ends June 30th and so their PC for [fiscal 1990] should have been filed on December 15th. It does not appear to have been submitted yet, and thus it should be easy for them to include additional information in it."

In a letter the same day to E. Lyndon Tefft, Harvard's director of financial systems, Allen informed him of the problems with the University's answers and asked for a response.

"Certain questions...were not fully answered," Allen wrote, also asking that the next year's Form PC include full responses.

But in a May 28, 1991 memo to Allen, Lund wrote, "[former General Counsel Daniel Steiner '54] says that they have filed their PC for [fiscal 1990] without making any changes in the ways they have been answering our questions, since it was already in the works when our letter arrived."

"Do you sense that we are getting ourselves into a position where we might have to review our form sooner than anticipated?" Lund continued.

"I really do not have a clear understanding of why we ask for all the information we do," he said.

In a subsequent meeting between Lund and Harvard attorney Pierce, Lund once again informed Pierce of the non-compliance.

"I showed her [Boston University's] most recent PC to illustrate how it apparently is possible to answer all the questions on the form and to supply the supplementary information requested," Lund wrote in an August 9, 1991 memo to her file.

Harvard had argued that listing details of its many financial transactions would be "burdensome."

In a memo to Allen the same day, Lund wrote, "Marianna and I met yesterday afternoon and reviewed the missing portions of the Harvard PC. I told her as a general proposition we'd like the information to be right there, rather than cross-referenced or 'available on request,' and that in particular the information about certain kinds of investments needed to be furnished in more detail than they were doing."

By late October 1991, when Lund again met with Pierce and Verne O. Sedlacek, chief financial officer of Harvard Management Company (the University's in-house endowment management group), the decision to revise the forms had been virtually finalized.

"I told them that we would be considering changes in the PC form, and if this were done it would presumably solve our difficulties with their filing," Lund wrote in a memo describing the meeting.

The memo further described recommendations Pierce and Sedlacek made for the revisions of the form.

Among other suggestions, the Harvard officials noted that "they do not want to list their 'nonpublic investments' and supply a value for them," according to the memo, because they said making the information public would put them at a competitive disadvantage.

"For example, apparently they have some sort of ownership interest in a Boston hotel," Lund wrote. "I gather they'd like to sell it. Publication of the value they place on it for their internal records is not going to help them negotiate a good price."