DATE:  December 28, 2007
In re:
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SSN: -----------
Applicant for Security Clearance
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ISCR Case No. 07-07400
DECISION OF ADMINISTRATIVE JUDGE
NOREEN A. LYNCH
APPEARANCES
FOR GOVERNMENT
Daniel F. Crowley, Esq., Department Counsel
FOR APPLICANT
Pro Se
SYNOPSIS
Applicant is a 59-year-old employee of a defense contractor. Due to her husband’s loss of
unemployment and low paying jobs, Applicant accumulated delinquent debt. Her financial
difficulties were exacerbated by separation and divorce. Applicant supports her adult two sons who
are not working. Applicant paid her four delinquent debts using inheritance money in September
2007. Applicant has mitigated the financial considerations concern.  Clearance is granted.
Pursuant to Exec. Or. 10865, Safeguarding Classified Information within Industry (Feb. 20, 1960), as amended1
and modified, and Department of Defense Directive 5220.6, Defense Industrial Personnel Security Clearance Review
Program  (Jan. 2, 1992), as amended (Directive).
GE 1 (Security Clearance Application, dated February 5, 2007).2
Tr. 68.3
Tr. 40.4
2
STATEMENT OF THE CASE
The Defense Office of Hearings and Appeals (DOHA) declined to grant or continue a
security clearance for Applicant. On September 19, 2007, DOHA issued a Statement of Reasons1
(SOR) detailing the basis for its decision–security concerns raised under Guideline F (Financial
Considerations) of the revised Adjudicative Guidelines (AG) issued on December 29, 2005, and
implemented by the Department of Defense for SORs issued after September 1, 2006. The revised
guidelines were provided to Applicant when the SOR was issued. Applicant answered the SOR on
October 12, 2007, and elected to have a hearing before an administrative judge. The case was
assigned to me on November 13, 2007. I scheduled a hearing for December 11, 2007.
The hearing was convened as scheduled on December 11, 2007 to consider whether it is
clearly consistent with the national interest to grant or continue a security clearance for Applicant.
Government exhibits (GE 1-4) were admitted. Testimony was taken from Applicant. Applicant’s
exhibits (AE A-M) were admitted. The transcript (Tr.) was received on December 19, 2007. 
FINDINGS OF FACT
Applicant admitted she once owed the creditors listed in the SOR, but denied the truth of the
factual allegations set forth in the SOR pertaining to financial considerations under Guideline F
(subparagraphs 1.a through 1.d.) because the debts are paid. Those admissions are incorporated as
findings of fact. After a complete and thorough review of the evidence in the record, I make the
following additional finding of fact:
Applicant is a 59-year-old employee of a defense contractor. She graduated from high school
in 1967. Applicant has been with her current employer since 1996 and has maintained a security
clearance with no problems.  She completed a security clearance application on February 6, 2007.2
Applicant married in September 1978. As a result of that marriage she has two sons. Her
husband lost his job as a systems analyst in the mid 1990's. According to Applicant, he was out of
work for more than two and a half years.  He was finally able to find a very low paying job.3
Applicant stayed at home with her sons until they started elementary school. She volunteered in a
school and then did some substitute teaching. Although she was employed occasionally, she did not
earn sufficient income to support the family and they began to accumulate debt.4
In 1996, Applicant started a temporary, full time position with her current company. In  1999,
Applicant was diagnosed with Muscular Dystrophy (MS). She states that it is a mild case, although
Tr. 43.5
Tr. 47.6
GE 2(Credit report, dated February 6, 2007).7
AE B; C; and D (Printout of Pay and Personal Financial Statement).8
Tr. 45.9
3
she wears an ankle brace to aid her walking. Her physician ordered a shot of Avonex as treatment.
She stopped taking the shots because she could not afford them. She also decided that she did not
really need them. 
In 2000, Applicant and her husband separated. At that time, she and her adult sons went to
live with her aunt who had a large home and property.  Her sons did not graduate from high school
and continue to have difficulty finding employment with limited skills. They live with Applicant and
she supports them. In 2001, when Applicant divorced, she was reduced to one small income.5
Applicant acknowledges that she used credit cards to help pay for items. When her television
stopped working, she replaced it but only paid on it for a while before she realized that she did not
have enough money to cover basic expenses. She admits using credit cards and taking out two loans
to help pay the bills. She regrets using credit cards and vows never to accumulate debt again.6
Applicant’s aunt died in November 2000. Another aunt died in 2003. At that time, Applicant
was to inherit half of the property and estate.  The family could not decide whether they wanted to
keep the property or sell it. This unresolved situation lingered for a few years. Applicant anticipated
the estate would be settled by 2005, but in the interim she was getting into debt with loans she
obtained to help pay her bills.  Her collection accounts began in late 2004-2005.  7
The status of Applicant’s  alleged debts as listed  in the SOR is as follows:
SOR ¶ Type of Account/Amount Status Evidence
1.a Collection account     $1,051 Paid AE L
1.b Collection account     $7,691 Paid AE G
1.c Collection account     $   358 Paid AE K
1.d Collection account     $9,993 Settled AE M; AE F
Applicant’s current net monthly income is $700 to 800.  After expenses, she has a small net8
monthly remainder.  She also helps an older neighbor and receives $50 every month for her service
as a care giver. In her current job there are wage increases each year. She is starting to save some
money. She is current on her rent and has no car payments. She does not use credit cards and has
incurred no new debts. She has pre-paid her car insurance for six months.  9
AE E (Real Estate Sales Agreement, dated June 2, 2007).10
AE F-M (Receipts)11
Tr. 62.12
AE A (Letters of Reference).13
Department of the Navy v. Egan, 484 U.S. 518, 528 (1988).14
Id. at 527.15
Exec. Or. 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960). 16
ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002).17
4
In August 2007, the inherited property was finally auctioned. Applicant received her half of
the distribution from the property.  She received approximately $71,000. She began to pay her debts10
immediately from that money. By September 25, 2007, all SOR debts were paid.  She has11
approximately $28,000 left from the inheritance in her savings account.
Applicant sought financial advice from two friends. Although they are not trained financial
counselors, they were helping Applicant with managing her money. The one friend is also her
landlord who was also advising her about investing her money. However, Applicant did not want
to invest any money before she paid all her debts.    12
Applicant has been employed with her current employer for almost 15 years. During that time
she has been involved with documents and security control. She has received various awards. She
has maintained her security clearance since 1993 with no problems. Applicant became a facility
security office last August. She needs a security clearance for that position. Her supervisor describes
Applicant as a person of character. He would not hesitate to employ her. Several co-workers describe
Applicant as loyal, well-rounded, and very likeable. One colleague describes Applicant as one of the
most honest, reliable people he knows. Several supervisors and co-workers praise her loyalty,
professionalism, composure, and financial management.13
POLICIES
“[N]o one has a ‘right’ to a security clearance.”  As Commander in Chief, the President has14
“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 authorized the Secretary of Defense or his designee to15
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 of16
demonstrating that it is clearly consistent with the national interest to grant or continue his or her
security clearance. The clearly consistent standard indicates that security clearance determinations
should err, if they must, on the side of denials.  Any reasonable doubt about whether an applicant17
should be allowed access to sensitive information must be resolved in favor of protecting such
Id.; Directive, ¶ E2.2.2.18
Exec. Or. 10865 § 7.19
AG ¶18.20
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sensitive information.  The decision to deny an individual a security clearance is not necessarily a18
determination as to the loyalty of an applicant.  It is merely an indication that the applicant has not
met the strict guidelines the President and the Secretary of Defense have established for issuing a
clearance.  19
The revised Adjudicative Guidelines set forth potentially disqualifying conditions (DC) and
mitigating conditions (MC) under each guideline. Additionally, each security clearance 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 the
Directive and AG ¶ 2(a).
Conditions 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 section 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.
Guideline F: Financial Considerations
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.  20
Applicant’s  delinquent debts totaling approximately $19,500 is not disputed. Thus, 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. Her admissions and credit
reports confirm the delinquent debts, and document her debt history.
Applicant used credit to purchase items that she could not afford and to help provide for her
adult sons after her divorce. She admits that she probably should not have replaced her television
when it ceased to work. She could have purchased a less expensive television as a replacement.  FC
DC 19(e) (consistent spending beyond one’s means, which may be indicated by excessive
indebtedness, significant cash flow, high debt-to-income ratio, and/or other financial analysis)
partially applies.
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
See ISCR 04-07360 at 2 (App. Bd. Sept. 26, 2006) (stating partial credit was available under FC MC 6 for21
debts resolved through garnishment).
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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 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).
Although FC MC 20 (a) does not provide a temporal or specific definition of what constitutes
“recent” conduct, Applicant’s overall conduct with creditors does not cast doubt on her current
reliability, trustworthiness and good judgment. She has shown sufficient unusual circumstances to
establish that her financial problems are “unlikely to recur.”Applicant’s separation and divorce after
years of her husband’s unemployment exacerbated her financial difficulties. She was determined to
support her adult sons who live with her because they are not working. Her delinquent debts occurred
in period of time from late 2004-2005. She has continued to work and be responsible. As soon as
she received her inheritance she paid all her debts. I find that FC MC 20(a) is partially applicable.
FC MC 20(b) is applicable for the reasons stated above.  21
Applicant has not received formal financial counseling. She has sought the advice of her
landlord and friends. She has paid all the debts that were delinquent and is in a stable job. FC MC
20 (c) applies due to the resolution of the debts. There are clear indications that the problem is under
control.
FC MC 20(d) is applicable because Applicant immediately paid her delinquent creditors
when she received the inheritance. She is current on all her other accounts and expenses. 
Whole Person Analysis
The adjudicative process is an examination of a sufficient period of a person’s life to make
an affirmative determination that the person is an acceptable security risk. Available, reliable
information about the person, past and present, favorable and unfavorable, should be considered in
reaching a determination. In evaluating Applicant’s case, I have considered the adjudicative process
factors listed in the Directive and AG ¶ 2(a). I have also considered all the evidence, and every
finding of fact and conclusion discussed above. 
Applicant has a long history of solid employment with her company. She is described as an
honest, trustworthy, reliable and capable person. She has held a security clearance since 1996. She
divorced in 2001 and supported her two sons with her income. After her husband’s unemployment
and loss of pay, Applicant began to accumulate debt. She did the best she could. She acknowledges
that the use of credit cards to finance her lifestyle was a mistake. She is now aware of the
consequences of using credit. She immediately paid her debts as soon as she received the inheritance.
She believed the estate would be settled shortly after 2003, but due to family conflicts about the sale
of the property that did not occur. She was candid and forthright at her hearing. She presented
documentation in an organized fashion. Her references all attest to her loyalty and reliability. She
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was credible in her resolve to handle her future financial situation. Her awareness and of financial
issues and solid job performance in her company persuade me that she is not vulnerable or a security
risk.
After weighing the disqualifying and mitigating conditions and evaluating all the evidence
in the context of the whole person, I conclude Applicant has mitigated the security concerns based
on her financial issues. She is eligible for a security clearance.
FORMAL FINDINGS
The following are my conclusions as to each allegation in the SOR:
Paragraph 1.  Guideline F: FOR APPLICANT
Subparagraph 1.a-1.d:             For Applicant
DECISION
In light of all of the circumstances presented by the record in this case, it is clearly consistent
with the national interest to grant or continue a security clearance for Applicant. Clearance is
granted.
Noreen A. Lynch
Administrative Judge