According to FBI records regulations and the Federal records act, “any document that is made in the…
Louis Weeks

Except, none of these meetings nor his writings were done on official business. Unless you believe that simply being the FBI director means that every encounter he has is considered official business. As he stated, he wrote these memos out on his time after encounters that the President engaged him with. Since the President was not under investigation and Comey was not briefing the President on any matters of concern for him none of it falls into the realm of being work related.

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