KEYWORD: Financial
DIGEST: Applicant incurred approximately $13,000 in delinquent debt, including many charged off
collection accounts. She provided no information concerning a plan to pay her creditors, and thus
failed to mitigate the security concerns raised under the financial considerations guideline.
Applicant’s eligibility for a security clearance is denied.
CASENO: 07-00202.h1
DATE: 07/17/2007
DATE:  July 17, 2007
In re:
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SSN: ------------
Applicant for Security Clearance 
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ISCR Case No. 07-00202
DECISION OF ADMINISTRATIVE JUDGE
NOREEN A. LYNCH
APPEARANCES
FOR GOVERNMENT
Julie R. Edmunds, Esq., Department Counsel
FOR APPLICANT
Pro Se
SYNOPSIS
Applicant incurred approximately $13,000 in delinquent debt, including many charged off
collection accounts. She provided no information concerning a plan to pay her creditors, and thus
failed to mitigate the security concerns raised under the financial considerations guideline.
Applicant's eligibility for a security clearance is denied.
This action was taken under Executive Order 10865, dated February 20, 1960, as amended, and DoD Directive1
5220.6, dated January 2, 1992, as amended and modified (Directive).
The government submitted five items in support of its contentions.2
Item 3 (Applicant’s Answer to SOR, dated March 19, 2007) at 1-3.3
Item 4 (Application for Security Clearance (SF 86), dated December 4, 2004) at 1-15.4
Id.5
2
STATEMENT OF THE CASE
On March 1, 2007, the Defense Office of Hearings and Appeals (DOHA) issued Applicant
a Statement of Reasons (SOR) stating that it was unable to find that it is clearly consistent with the
national interest to grant or continue a security clearance.  The SOR, which is in essence the1
administrative complaint, alleged security concerns under Guideline F (Financial Considerations)
of the revised Adjudicative Guidelines (AG) issued on December 29, 2005, and implemented by the
Department of Defense effective September 1, 2006. The revised guidelines were provided to
Applicant when the SOR was issued.
On March 19, 2007, Applicant submitted a notarized response to the SOR, and elected to
have her case decided on the record in lieu of a hearing. Department Counsel submitted the
Government’s written case on April 16, 2007. Applicant received a complete file of relevant material
(FORM) on April 23, 2007, and was provided the opportunity to file objections and submit material
to refute, extenuate, or mitigate the Government’s case.   Applicant did not submit any additional2
information. The case was assigned to me on June 28, 2007. 
FINDINGS OF FACT
Applicant admitted  allegations in subparagraphs  1.b through 1. h in her SOR response under
Guideline F. She denied allegation 1.a. with no explanation.  The admissions are incorporated as3
findings of fact. After a complete review of the evidence in the record and upon due consideration,
I make the following additional findings of fact:
Applicant is a 44-year-old employee of a defense contractor. After she graduated from high
school, she attended college. In 1992 she received her associate of arts degree. She has worked for
her current employer since 1993. She was divorced in 1984, but she is remarried with three children.4
On December 4, 2004, she completed her security clearance (SF 86) application.5
Applicant was steadily employed after college. She held a design specialist position for  years
and reported no unemployment. Applicant did not provide any details about her work record. 
Item 3, supra note 3, at 1-2.6
Item 5 (Credit Bureau Report, dated January 9, 2007) at 1-4.7
 Department of the Navy v. Egan, 484 U.S. 518, 527 (1988).  8
 Directive, ¶ E2.2.1.9
 Directive, Revised Adjudicative Guidelines (AG) 2 (a)(1)-(9).10
 Id.11
3
Applicant’s debts in the SOR total approximately $13,000. She denied one debt in the SOR
in the amount of $132.   However, the debt is still on her recent credit report.  Multiple accounts6
were charged off or placed for collection. Several of the debts have been in collection since 2003.7
Applicant provided no details or information concerning the debts, her inability to pay, or her
intention to pay them.
POLICIES
The President has “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.”   In Executive Order 10865, Safeguarding8
Classified Information Within Industry (Feb. 20, 1960), the President set out guidelines and
procedures for safeguarding classified information and determining trustworthiness within the
executive branch. 
To be eligible for a security clearance or access to sensitive information, an applicant must
meet the security guidelines contained in the Directive.  The revised Adjudicative Guidelines set forth
potentially disqualifying conditions (DC) and mitigating conditions (MC) under each guideline.
Additionally, each security decision must be a fair and impartial commonsense decision based on the
relevant and material facts and circumstances, the whole-person concept, along with the adjudicative
process factors listed in ¶ 6.3 of the Directive, and AG ¶ 2(a).
“The adjudicative process is an examination of a sufficient period of a person’s life to make
an affirmative determination that the person is eligible for a security clearance.”    An administrative9
judge must apply the “whole person concept,” and consider and carefully weigh the available, reliable
information about the person.   An administrative judge should consider the following factors: (1)10
the nature, extent, and seriousness of the conduct; (2) the circumstances 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 voluntariness of participation; (6) the
presence or absence of rehabilitation and other pertinent 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.   11
 Directive, ¶ E3.1.14.12
 Directive, ¶ E3.1.15.13
 ISCR Case No. 01-20700 at 3 (App. Bd. December 19, 2002).14
 Directive, ¶ E2.2.2.15
AG ¶ 18.16
4
Initially, the Government must present evidence to establish controverted facts in the SOR that
disqualify or may disqualify the applicant from being eligible for access to classified information.12
Thereafter, the applicant is responsible for presenting evidence to rebut, explain, extenuate, or
mitigate the facts.  An applicant “has the ultimate burden of demonstrating that it is clearly consistent13
with the national interest to grant or continue his security clearance.”  Any doubt as to whether14
access to classified information is clearly consistent with national security will be resolved in favor
of the national security.  The same rules apply to trustworthiness determinations for access to15
sensitive positions.
CONCLUSIONS
I have carefully considered all the facts in evidence and the legal standards. The government
has established a prima facie case for disqualification under Guideline F of the revised Adjudicative
Guidelines (AG) most pertinent to the evaluation of the facts in this case.
 
Guideline F (Financial Considerations) The Concern: 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.16
In this matter, the government provided substantial evidence that Applicant accrued  delinquent
debts with an approximate total balance of $13,000. She admits they are still outstanding debts except
for one. Her 2007 credit report confirms all her alleged debts. Consequently, Financial Considerations
Disqualifying Conditions (FC DC) AG ¶19(a) (inability or unwillingness to satisfy debts) and FC DC
AG ¶19 (c) (a history of not meeting financial obligations) apply. 
With the government’s case established, the burden shifts to Applicant to present evidence of
refutation, extenuation, or mitigation to overcome the case against her. I considered the Financial
Considerations Mitigating Condition (FC MC) AG ¶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). It does not apply because
Applicant still carries a significant amount of delinquent debt. One collection account is from 2000.
Despite steady employment, these numerous debts are delinquent. She provided no explanation of
special circumstances.
5
She has been in her current position since 1993. She has not provided evidence or explanation
to support the FC MC AG ¶20 (b) (the conditions that resulted in the behavior 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).
I have considered the remaining mitigating conditions and find that none of them apply. FC
MC AG¶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 under control); FC MC AG ¶ 20 (d) (the
individual initiated a good-faith effort to repay overdue creditors or otherwise resolve debts);FC MC
AG ¶20(e) (the individual has a reasonable basis to dispute the legitimacy of the past-due debt which
is the cause of the problem and provides documented proof to substantiate the basis of the dispute or
provides evidence of actions to resolve the issue) 
Applicant has not received financial counseling or developed a structured plan to resolve these
debts. Applicant's financial problems remain. It is unlikely they will be resolved in the near future.
Applicant has not shown that she established a record of steady payments or financial stability.  Thus,
I conclude that she has not made a good-faith effort to resolve her debts. This is confirmed debt on her
2007 credit report.
The issue is not whether Applicant is still legally liable for any or all of her outstanding debts,
but whether she has presented sufficient evidence of extenuation, mitigation or changed circumstances
to warrant a favorable security determination. Her remaining unpaid debt constitutes a security
concern.  She has been employed with her current employer since 1993. She has  she has chosen not
to resolve her delinquent debts. Applicant has not mitigated the government’s concerns under
Guideline F.
Whole Person
In all adjudications, the protection of our national security is the paramount concern. The
objective of the trustworthy determination process is the fair-minded, commonsense assessment of a
person’s life to make an affirmative determination that the person is eligible for assignment to sensitive
duties. 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 their 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.
I have considered all the evidence and the “whole person” in evaluating Applicant’s security
clearance determination.  Even an applicant with a good or even exemplary work history may engage
in conduct that has negative implications or presents doubt about her judgment. Despite steady
employment, Applicant has accrued multiple delinquent accounts. It is not clearly consistent with the
national interest to grant Applicant a security clearance. Clearance is denied.
FORMAL FINDINGS
6
Formal Findings for or against Applicant on the allegations set forth in the SOR, as required
by Section E3.1.25 of Enclosure 3 of the Directive, are:
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
DECISION
In light of all of the circumstances presented by the record in this case, it is not clearly
consistent with national interest to grant Applicant’s request for a security clearance. Clearance is
denied.
Noreen A. Lynch
Administrative Judge