DATE:  November 30, 2007
In re:
----------------------              
SSN: -----------
Applicant for Security Clearance
)
)
)
)
)
)
)
)
ISCR Case No. 06-24030
DECISION OF ADMINISTRATIVE JUDGE
ARTHUR E. MARSHALL, JR.
APPEARANCES
FOR GOVERNMENT
Eric Borgstrom, Esq., Department Counsel
FOR APPLICANT
Pro Se
SYNOPSIS
Applicant is a 61-year-old administrative aide for a federal contractor. Between 2000 and
2006, over $26,000 of her debts became delinquent. She introduced no documentation and presented
scant argument mitigating financial considerations security concerns. Clearance is denied. 
STATEMENT OF THE CASE
On May 30, 2007, the Defense Office of Hearings and Appeals (DOHA), pursuant to
Executive Order 10865, Safeguarding Classified Information Within Industry, dated February 20,
1960, as amended and modified, and Department of Defense Directive 5220.6, Defense Industrial
Personnel Security Clearance Review Program (Directive), dated January 2, 1992, as amended and
modified, issued a Statement of Reasons (SOR). That SOR detailed reasons why, pursuant to
Guideline F (Financial Considerations), it could not make the preliminary affirmative finding under
 The Government submitted nine items in support of its case.1
 See SOR allegation 1.a.
2
 Answer to the SOR at 3.
3
2
the Directive that it is clearly consistent with the national interest to grant or continue a security
clearance for Applicant. In her response, notarized on June 14, 2007, Applicant admitted all seven
allegations set forth in the SOR. This included six allegations regarding past due accounts totaling
almost $20,000 and one allegation regarding a garnishment imposed against her wages for a
delinquent debt in the approximate amount of $6,793.53. She also submitted a one-page explanation
regarding the debt noted in the first SOR allegation, a delinquent account to an automobile company
for approximately $11,047. Additionally, Applicant requested an administrative determination based
on the written record.
The Government’s case was submitted on July 11, 2007, and a complete copy of the file of
relevant material (FORM)  was provided to Applicant. She received a copy of the FORM on1
September 5, 2007, and was afforded the opportunity to file objections and submit evidence in
refutation, extenuation, or mitigation. A one-page, hand written letter, dated October 3, 2007, was
submitted by Applicant. It provided additional comment regarding some of her delinquent accounts.
That submission was made part of the record without objection from the Government. I was assigned
this case on November 28, 2007.
FINDINGS OF FACT
Applicant’s admissions to all of the allegations set forth in the SOR are incorporated herein.
After a complete and thorough review of the evidence in the record, I make the following additional
findings of fact:
Applicant is a 61-year-old administrative aide for a federal contractor. She has worked for
that contractor since 1986 and has held a security clearance since that time without incident. The
mother of a 32-year-old daughter, Applicant was married from 1974 through 1981. 
There are few facts of record depicting Applicant’s life or finances and Applicant chose to
limit her submissions and narrative to a minimum. At issue are seven obligations, amounting to over
$26,000 in delinquent debts. These debts went into collection at various dates between 2000 and
2006. 
With regard to a collection account by an automobile manufacturer for approximately
$11,047, that account was put into collection in October 2006 and was still unsatisfied as of March
2007.  Applicant only notes: “I just feel I was railroaded into signing anything. I didn’t even have2
any intention of buying anything. . . . My daughter was the one wanting to look, but she didn’t have
a job and she was on state [illegible]. So how is it they can make her a co-signer on this and no bank
would give me a loan.”  She continues by noting: “It was poor judgment on my part with a signature,3
 Id.
4
 ISCR Case No. 96-0277 at 2 (App Bd. Jul. 11, 1997).5
 ISCR Case No. 97-0016 at 3 (App Bd Dec 31, 1997), Directive, Enclosure 3, ¶ E3.1.14.6
3
but I already had a 254.00 dollar car note with [a bank] and some how they finagled a way to make
this loan go through using [the creditor’s] motor company.”4
In Applicant’s response to the FORM, she made some additional comments regarding
specific allegations. Regarding SOR allegation 1.g, the garnishment for approximately $6,793.53,
Applicant states she only has five more weeks of $50 payments before the balance is satisfied. She
also gives the name and phone number of a bank contact person. No other information or
documentation was submitted.
Applicant also states that “in November I’ll be working on the telephone bills with the money
that has been paying the credit card amount.” Although SOR allegation 1.c, for about $392, is clearly
a telecommunications company, it is unclear as to what other account(s) Applicant is making
reference with this statement. 
Finally, Applicant states: “The personal Subject Interview. The rent figure of 815.00 a month
is 875 a month. That maybe a typo.” This comment is made to apparently correct a statement made
by her in the FORM. No other illustrative or mitigating information is provided by Applicant.
POLICIES
Enclosure 2 of the Directive sets forth adjudicative guidelines to be considered in evaluating
a person’s eligibility to hold a security clearance. Included in the guidelines are disqualifying
conditions (DC) and mitigating conditions (MC) applicable to each specific guideline. Additionally,
each security clearance decision must be a fair, impartial, and commonsense decision based on the
relevant and material facts and circumstances; it must be based on its own merits, with consideration
of the whole-person concept, and in light of the factors listed in the Directive. Specifically these
factors are: (1) 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 incident;(5) the extent to which the
participation is 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 adjudicative guidelines should be followed whenever a case can be measured against this policy
guidance.
The sole purpose of a security clearance determination is to decide if it is clearly consistent
with the national interest to grant or continue a security clearance for an applicant.  The government5
has the burden of proving controverted facts.  The burden of proof is something less than a6
Department of the Navy v. Egan, 484 U.S. 518, 531 (1988).7
 ISCR Case No. 94-1075 at 3-4 (App Bd. Aug. 10, 1995); Directive, Enclosure 3, ¶ E3.1.15.
8
 ISCR Case No. 93-1390 at 7-8 (App Bd. Jan. 27, 1995); Directive, Enclosure 3, ¶ E3.1.15.
9
 Egan, 484 U.S. at 531.10
 Id.11
 Id.; Directive, Enclosure 2, ¶ E2.2.2.12
 Executive Order 10865 § 7.
13
 AG ¶ 18.
14
4
preponderance of evidence.  Once the government has met its burden, the burden shifts to an7
applicant to present evidence of refutation, extenuation, or mitigation to overcome the case against
her.  Additionally, an applicant has the ultimate burden of persuasion to obtain a favorable clearance8
decision.9
No one has a right to a security clearance  and “the clearly consistent standard indicates that10
security clearance determinations should err, if they must, on the side of denials.”  Any reasonable11
doubt about whether an applicant should be allowed access to sensitive information must be resolved
in favor of protecting such sensitive information.  The decision to deny an individual a security12
clearance is not necessarily a determination as to the loyalty of an applicant.  It is merely an13
indication that the applicant has not met the strict guidelines the President and the Secretary of
Defense have established for issuing a clearance.
Based upon consideration of the evidence, I find the following adjudicative guideline most
pertinent to the evaluation of the facts in this case:
Guideline F - Financial Considerations. The Concern: Failure or an 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.14
Conditions pertaining to this adjudicative guideline (AG) that could raise a security concern
and may be disqualifying, as well as those which would mitigate security concerns, are set forth and
discussed in the conclusions below.
CONCLUSIONS
 See SOR allegation 1.a.
15
 See SOR allegation 1.g.
16
 This is particularly true since Applicant failed to identify exactly which of the cited obligations were to be
17
satisfied with those sums. 
5
Upon consideration of all the facts in evidence and Applicant’s admissions to the seven SOR
allegations, and after application of all legal precepts, factors, and conditions, I find the following
with respect to the allegations set forth in the SOR:
With respect to Guideline F (Financial Considerations), the Government has established its
case. Applicant admits, as alleged, that she has seven delinquent accounts. Those accounts comprise
a past-due debt of over $26,000. Therefore, Financial Considerations Disqualifying Condition (FC
DC) 1, AG ¶ 19(a), (inability or unwillingness to satisfy debts) and FC DC 2, ¶ 19(c) (a history of not
meeting financial obligations) apply. Given this showing, the burden shifts to Applicant to present
evidence of refutation, extenuation, or mitigation, to overcome the case against her.  
With regard to the first obligation cited, it appears that Applicant wishes to argue that she did
not think her signature as a co-signor, or that of her daughter, would effectuate the loan which would
provide one or both of them with an automobile.  While the argument is unclear, the fact is that a15
loan was entered into for an automobile and that the account was placed into collection in October
2006. Although her statement is somewhat vague, there is no indication as to what, if anything, has
been done with the car or the account. No mention is made of a voluntary repossession, an attempt
to work out an alternative repayment plan, or any other action which might tend to show that
Applicant attempted to address this substantial and delinquent obligation.
Moreover, although Applicant states she is almost through repaying one credit card
obligation  through garnishment, she provides only the name and telephone number of a bank16
contact. While, at best, this unsubstantiated declaration might serve to suggest some progress toward
one obligation has been made, she has failed to submit any documentation reflecting any genuine
progress on this garnishment or showing her current balance owed. Consequently, she has failed to
meet her burden with regard to this account and this allegation. Further, while it may be Applicant’s
intent to eventually satisfy her telephonic obligations with the sums now devoted to repaying this
credit card garnishment, a promise to pay in the future provides no tangible evidence that actual
progress has been made or will be made on a debt or debts.  17
When Applicant chose to have this matter decided on the written record, she precluded the
possibility of oral testimony and inquiry which might have elicited sufficient facts to raise one of the
available Financial Considerations Mitigating Conditions (FC MC). Based on the scant facts of
record, however, none of the FC MCs have been raised and Applicant has failed in her burden to
overcome the case against her.
Given the few facts of record, a whole person analysis must be made on minimal facts.
Applicant is a mature woman with a grown daughter and a career. Applicant has worked for a federal
contractor for over 20 years. Similarly, she has held a security clearance for over two decades. Despite
her familiarity with security clearances and the clearance process, Applicant failed to present any
special facts or circumstances that might explain how these seven obligations became delinquent
between 2000 and 2006. Indeed, although based on her unsubstantiated assertions and scant argument,
6
it appears that only the debt subject to a garnishment has been actually addressed. While Applicant
expresses plans to address some of her other debts in the future, she has failed to tangibly document
any past or present efforts which might mitigate the serious security concerns posed by the financial
considerations guideline. Consequently, Applicant failed to demonstrate that it is clearly consistent
with the national interest to grant her a security clearance. Because any doubts must be resolved in
favor of the national security, I find all the allegations set forth in the SOR in the Government’s favor.
Clearance is denied.
FORMAL FINDINGS
Formal findings For or Against Applicant on the allegations set forth in the SOR, as required
by Section E3.1.2.5 of Enclosure 3 of the Directive, are:
Paragraph 1, Guideline F: AGAINST THE APPLICANT
Subparagraph 1.a: Against the Applicant
Subparagraph 1.b: Against the Applicant
Subparagraph 1.c: Against the Applicant
Subparagraph 1.d: Against the Applicant
Subparagraph 1.e: Against the Applicant
Subparagraph 1.f: Against the Applicant
Subparagraph 1.g: Against the Applicant
DECISION
In light of all the circumstances presented by the record in this case, it is not clearly consistent
with the national interest to grant a security clearance for Applicant. Clearance is denied.
Arthur E. Marshall, Jr.
Administrative Judge