KEYWORD: Financial
DIGEST: Applicant is 46 years old and has been employed by a federal contractor as a custodian
since November 2004. She has been steadily employed since 1998. She has two children. Applicant
has eleven delinquent debts totaling approximately $8,000 that remain unpaid. Ten of the debts have
been placed for collection and one is charged off. The debts date back to 2002 through 2006.
Applicant failed to provide amplifying information as to any action she has taken to pay or resolve
her debts. Applicant failed to mitigate the security concerns under Guideline F, financial
considerations. Clearance is denied. 
CASENO: 06-21244.h1
DATE: 05/31/2007
DATE: May 31, 2007
In re:
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SSN: ------------
Applicant for Security Clearance
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ISCR Case No. 06-21244
DECISION OF ADMINISTRATIVE JUDGE
CAROL G. RICCIARDELLO
APPEARANCES
FOR GOVERNMENT
Rita C. O'Brien, Esq., Department Counsel
FOR APPLICANT
Pro Se
SYNOPSIS
Item 4.1
Item 3.2
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Applicant is 46 years old and has been employed by a federal contractor as a custodian since
November 2004. She has been steadily employed since 1998. She has two children. Applicant has
eleven delinquent debts totaling approximately $8,000 that remain unpaid. Ten of the debts have
been placed for collection and one is charged off. The debts date back to 2002 through 2006.
Applicant failed to provide amplifying information as to any action she has taken to pay or resolve
her debts. Applicant failed to mitigate the security concerns under Guideline F, financial
considerations. Clearance is denied.
STATEMENT OF THE CASE
The Defense Office of Hearings and Appeals (DOHA) declined to grant or continue a
security clearance for Applicant. DOHA issued a Statement of Reasons (SOR) on November 28,
2006, detailing the basis for its preliminary decision–security concerns raised under Guideline F
(Financial Considerations). This action was taken under Executive Order 10865, Safeguarding
Classified Information within Industry (Feb. 20, 1960), as amended and modified, Department of
Defense Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (Jan.
2. 1992), as amended and modified (Directive), and the revised adjudicative guidelines approved by
the President on December 29, 2005, and implemented effective September 1, 2006 (Guidelines).
In Applicant’s undated answer to the SOR, she elected to have her case decided on the written
record. Department Counsel submitted the government’s file of relevant material (FORM) on
February 28, 2007. The FORM was mailed on March 1, 2007, and received on March 9, 2007.
Applicant was afforded an opportunity to file objections and submit material in refutation,
extenuation, or mitigation. Applicant did not provide any additional information. The case was
assigned to me on May 24, 2007. 
FINDINGS OF FACT
Applicant’s admissions to the allegations in the SOR are incorporated herein. In addition,
after a thorough and careful review of the pleadings, exhibits, and testimony, I make the following
findings of fact.
Applicant is 46 years old and has been employed as a custodian for a federal contractor since
November 2004. She has two children, whose ages were not provided. In her security clearance
application (SCA) Applicant listed that she has been steadily employed since May 1998.1
Applicant admitted she owes all the debts listed in the SOR, except the debt in subparagraph
1.k, that was resolved through a court proceeding and the debt was dismissed.  Applicant stated the2
debt in subparagraph 1.f was incurred while she was unemployed. However, this debt was placed
for collection in January 2003. This assertion contradicts Applicant’s SCA that lists she has been
Id.3
Id.4
Department of the Navy v. Egan, 484 U.S. 518, 528 (1988).5
Id. at 527.6
Exec. Or. 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960). 7
ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002).8
Id.9
Id.; Directive, Enclosure 2, ¶ E2.2.2.10
Executive Order 10865 § 7.11
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steadily employed since 1998. Applicant stated she is unable to pay this debt “at this time.”3
Applicant did not provide any amplifying information as to what action she intends to take to pay
it in the future or resolve it otherwise. Applicant also stated she had been receiving some child
support payments for her children from their father and then it abruptly stopped.  She failed to4
provide any other amplifying information about the ages of her children and what efforts she has
taken, if any, to pursue child support payments.
Applicant did not provide any information to show she is attempting to resolve any of the
debts listed in the SOR. She did not provide any information as to why the debts were incurred and
why they are delinquent. She has eleven delinquent debts. Ten debts are in a collection status and
one debt was charged off in July 2005. The oldest debt was placed for collection in December 2002
and the most recent was placed for collection in June 2006. No information was provided as to
Applicant’s income status or if she has received any financial counseling. 
POLICIES
“[N]o one has a ‘right’ to a security clearance.”  As Commander in Chief, the President has5
“the authority to . . . control access to information bearing on national security and to determine
whether an individual is sufficiently trustworthy to occupy a position . . . that will give that person
access to such information.”  The President has authorized the Secretary of Defense or his designee6
to grant applicants eligibility for access to classified information “only upon a finding that it is
clearly consistent with the national interest to do so.”  An applicant “has the ultimate burden of7
demonstrating that it is clearly consistent with the national interest to grant or continue his security
clearance.”  “The clearly consistent standard indicates that security clearance determinations should8
err, if they must, on the side of denials.”  Any reasonable doubt about whether an applicant should9
be allowed access to sensitive information must be resolved in favor of protecting such sensitive
information.  The decision to deny an individual a security clearance is not necessarily a10
determination as to the loyalty of an applicant.  It is merely an indication that the applicant has not11
See Exec. Or. 10865 § 7.12
See Egan, 484 U.S. at 531.13
See v. Washington Metro. Area Transit Auth., 36 F.3rd 375, 380 (4th Cir. 1994).14
See ISCR Case No. 95-0611 at 2 (App. Bd. May 2, 1996)15
See Directive ¶ E3.1.15.16
ISCR Case No. 01-207000 at 3 (App. Bd. Dec. 19, 2002)17
Egan, 484 U.S. at 531; see Guidelines ¶ 2(b).18
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met the strict guidelines the President and the Secretary of Defense have established for issuing a
clearance.12
Initially, the government must establish, by substantial evidence, conditions in the personal
or professional history of the applicant which disqualify, or may disqualify, the applicant from being
eligible for access to classified information.  “Substantial evidence” is “more than a scintilla but less13
than a preponderance.”  The Guidelines presume a nexus or rational connection between proven14
conduct under any of the criteria listed therein and an applicant’s security suitability.15
Once the government establishes a disqualifying condition by substantial evidence, the
burden shifts to the applicant to rebut, explain, extenuate, or mitigate the facts.  An applicant “has16
the ultimate burden of demonstrating that it is clearly consistent with the national interest to grant
or continue his security clearance.”  “[S]ecurity clearance determinations should err, if they must,17
on the side of denial.”18
Conditions that could raise a security concern and may be disqualifying, as well as those
which would mitigate security concerns, pertaining to the adjudicative guideline is set forth and
discussed in the conclusions below.
CONCLUSIONS
I have carefully considered all the facts in evidence and the legal standards discussed above.
I reach the following conclusions regarding the allegations in the SOR.
Based upon consideration of the evidence, I find the following adjudicative guideline most
pertinent to the evaluation of the facts in this case:
Financial Considerations are a security concern because failure or inability to live within
one’s means, satisfy debts, and meet financial obligations may indicate poor self-control, lack of
judgment, or unwillingness to abide by rules and regulations, all of which can raise questions about
an individual’s reliability, trustworthiness and ability to protect classified information. An individual
who is financially overextended is at risk of having to engage in illegal acts to generate funds.
Compulsive gambling is a concern as it may lead to financial crimes including espionage. Affluence
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that cannot be explained by known sources of income is also a security concern. It may indicate
proceeds from financially profitable criminal acts. 
Based on all the evidence, Financial Considerations Disqualifying Condition (FC DC) 19(a)
(inability or unwillingness to satisfy debts) and FC DC 19(c) (a history of not meeting financial
obligations), apply in this case. Applicant has many debts that have been delinquent for years with
no action toward resolving them and no information or indication that she intends on paying them.
I have considered all the Financial Considerations Mitigating Conditions (FC MC), and
especially considered FC MC 20(a) (the behavior happened so long ago, was so infrequent, or
occurred under such circumstances that it is unlikely to recur and does not cast doubt on the
individual’s current reliability, trustworthiness, or good judgment), FC MC 20(b) (the conditions
that resulted in the financial problem were largely beyond the person’s control (e.g., loss of
employment, a business downturn, unexpected medical emergency, or a death, divorce or
separation), and the individual acted responsibly under the circumstances), FC MC 20(c) (the
person has received or is receiving counseling for the problem and/or there are clear indications
that the problem is being resolved or is under control), and FC MC 20(d) (the individual initiated
a good-faith effort to repay overdue creditors or otherwise resolve debts). Applicant’s debts are
recent and unpaid and she failed to provide any information as to her intent to resolve them. The lack
of information on any good-faith effort to repay or take action on the debts and the age of the debts
casts doubt on her reliability and good judgment. Applicant alluded to a period of unemployment;
however, this contradicted her SCA where she listed she had been steadily employed since 1998. She
also stated she had been receiving child support, but it stopped. She did not provide enough
information to show she took any action to pursue reinstatement of the payments. Applicant was
employed when her debts became delinquent. She has not shown the conditions that may have
caused her financial problems were beyond her control, or that she has acted responsibly under the
circumstances. Applicant has not provided any evidence that she intends to pay her delinquent debts
or has made a good-faith effort to resolve them. Therefore, I find none of the above mitigating
conditions apply. 
Whole Person Analysis
In all adjudications, the protection of our national security is the paramount concern. The
objective of the security-clearance process is the fair-minded, commonsense assessment of a person’s
life to make an affirmative determination that the person is eligible for a security clearance. Indeed,
the adjudicative process is a careful weighing of a number of variables in considering the “whole
person” concept. It recognizes that we should view a person by the totality of his or her acts,
omissions, motivations and other variables. Each case must be adjudged on its own merits, taking
into consideration all relevant circumstances, and applying sound judgment, mature thinking, and
careful analysis.
In addition to considering the specific disqualifying and mitigating conditions under the
guideline, I have also considered the adjudicative process factors listed in ¶ 2a (1)-(9) of the
Guidelines to be considered in evaluating a person’s eligibility to hold a security clearance.
Specifically these are: (1) the nature, extent and seriousness of the conduct; (2) the circumstances
and surrounding the conduct to include knowledgeable participation; (3) the frequency and recency
of the conduct; (4) the individual’s age and maturity at the time of the conduct; (5) the extent to
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which participation was voluntary; (6) the presence or absence of rehabilitation and other permanent
behavioral changes; (7) the motivation for the conduct; (8) the potential for pressure, coercion,
exploitation, or duress; and (9) the likelihood of continuation or recurrence. Although the presence
or absence of a particular condition or factor for or against clearance is not outcome determinative,
the Guidelines should be followed whenever a case can be measured against this policy guidance.
I considered the whole person in evaluating the case. I considered all of the information
provided in Applicant’s answer and the attached documents.
After weighing the disqualifying and mitigating conditions under Guideline F and evaluating
all the evidence in the context of the whole person, I conclude Applicant has not mitigated the
security concerns based on financial considerations. Accordingly, I conclude she has not carried her
burden of showing that it is clearly consistent with the national interest to grant her a security
clearance.
FORMAL FINDINGS
The following are my conclusions as to each allegation in the SOR:
Paragraph 1. Guideline F: AGAINST APPLICANT
Subparagraph 1.a: Against Applicant
Subparagraph 1.b: Against Applicant
Subparagraph 1.c: Against Applicant
Subparagraph 1.d: Against Applicant
Subparagraph 1.e: Against Applicant
Subparagraph 1.f: Against Applicant
Subparagraph 1.g: Against Applicant
Subparagraph 1.h: Against Applicant
Subparagraph 1.i: Against Applicant
Subparagraph 1.j: Against Applicant
Subparagraph 1.k: For Applicant
Subparagraph 1.l: Against Applicant
DECISION
In light of all of the circumstances in this case, it is not clearly consistent with the national
interest to grant or continue a security clearance for Applicant. Clearance is denied.
Carol G. Ricciardello
Administrative Judge