1
                                                             
                           DEPARTMENT OF DEFENSE   
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
 ----------------------------- )     ISCR Case No. 07-15056
SSN: --------------------- )
)
Applicant for Security Clearance )
Appearances
For Government: Eric H. Borgstrom, Esquire, Department Counsel
For Applicant: Pro se
______________
Decision
______________
MATCHINSKI, Elizabeth M., Administrative Judge:
Applicant submitted an Electronic Questionnaire for Investigations Processing (e-
QIP) on April 17, 2007. On July 14, 2008, the Defense Office of Hearings and Appeals
(DOHA) issued a Statement of Reasons (SOR) to Applicant detailing the security
concerns under Guideline F that provided the basis for its decision to deny her a
security clearance and refer the matter to an administrative judge. The action was taken
under Executive Order 10865, Safeguarding Classified Information within Industry
(February 20, 1960), as amended; Department of Defense Directive 5220.6, Defense
Industrial Personnel Security Clearance Review Program (January 2, 1992), as
amended (Directive); and the revised adjudicative guidelines (AG) promulgated by the
President on December 29, 2005, and effective within the Department of Defense as of
September 1, 2006.
Applicant acknowledged receipt of the SOR on July 24, 2008. She answered the
SOR allegations in writing on August 20, 2008, and requested a hearing. The case was
assigned to me on September 3, 2008, to conduct a hearing and to determine whether it
is clearly consistent with the national interest to grant or continue a security clearance
for Applicant. On October 6, 2008, Applicant requested a delay in holding her hearing
Applicant testified with no evidence to the contrary that the debt in SOR ¶ 1.b was incurred by her1
parents who used the credit card for college-related expenses, including travel to and from the university. She
admitted she initiated the account but charged only about $60 on the card (Tr. 99).
Applicant denied the debts in SOR ¶¶ 1.a and 1.l, but not the debt in SOR ¶ 1.m.  Based on the credit2
reports, they likely all pertain to the same debt. As reported in May 2007 (Ex. 4), the creditor in SOR ¶ 1.l
reported a $2,349 debt balance for collection in November 2004. The collection agency in SOR ¶ 1.m opened
its account in November 2004 with a balance of $2,350. The named original creditor, Associates, is likely a
prior assignee. The creditor named in SOR ¶ 1.a then obtained a judgment of $2,349 in April 2007, which is
the reported balance of the debt in SOR ¶ 1.l. The updated credit report of June 25, 2008, reports only the
$2,349 judgment and does not include either of the creditors named in SOR ¶¶ 1.l or 1.m.
2
until January 2009 due to the unexpected hospitalization of her newborn. Then
assigned Department Counsel Gina Marine did not object, and on October 9, 2008, I
granted her request. On December 8, 2008, I scheduled a hearing for January 8, 2009.
The parties appeared as scheduled. Four government exhibits (Ex. 1-4) and
three Applicant exhibits (Ex. A-C) were admitted. Applicant and her spouse testified, as
reflected in a transcript received on January 28, 2009. The record was held open until
January 26, 2009, for Applicant to submit additional documentation. On January 23,
2009, Applicant submitted a statement concerning creditor contacts and her plans to
repay outstanding accounts (Ex. D), a current personal financial statement (Ex. E), a
recent wage and earnings statement for her spouse (Ex. F) and herself (Ex. G), and a
character reference letter (Ex. H). Department Counsel did not object and the
documents were marked and admitted into the record as noted. Based on a review of
the SOR, Answer, transcript, and documentary exhibits, eligibility for access to
classified information is granted.
Findings of Fact
DOHA alleged under Guideline F, financial considerations, that Applicant owes
delinquent debt totaling $18,853 (SOR ¶¶ 1.a through 1.s). Applicant denied the debts
alleged in SOR ¶¶ 1.a, 1.j, 1.k, 1.l, and 1.o, but admitted the other debts. After
considering the evidence of record, I make the following findings of fact.
Applicant is a 28-year-old business operations clerk who has worked on a U.S.
military installation since March 2007. She stayed on in her position after the company
that had hired her lost the contract (Tr. 81, 114). Applicant has an interim security
clearance for her duties (Tr. 81).
In the fall of 1998, Applicant began undergraduate studies at a public university.
She financed her education through student loans totaling about $50,496 (Ex. 4), some
financial support from her parents, and seasonal income as a sales associate for a
department store over the holidays in 1999 (Ex. 1). She obtained several credit card
accounts in her name over the 1998/99 time frame (SOR ¶¶ 1.b, 1.h, 1.i, 1.l,  1.n, 1.p,1 2
1.q, and 1.r) (Ex. 4). Applicant paid her credit card bills on time until 2001. In November
2000, she lost her student research position after the professor for whom she had been
working left the university (Ex. 1, Tr. 83).
3
In June 2001, Applicant transferred to another campus of the same university
(Ex. 1). Her father lost his job that fall, and her parents had to reduce their financial
support by 75% (Tr. 84). In addition to working as a student recruiter for the university
until January 2004, Applicant held several other jobs while going to college. She worked
as a cashier for a lingerie store from July to December 2001, and was a semi-
professional cheerleader part-time from August 2001 to August 2002. Her income was
not sufficient to pay off her credit card balances in full each month so she just stopped
paying on her credit cards (SOR ¶¶ 1.h, 1.i, 1.l, 1.n, 1.p, 1.q, and 1.r) (Ex. 4). She
notified her creditors that she was unable to pay on her credit cards but they refused her
request to close the accounts and interest continued to accrue (Tr. 102). 
In February 2003, Applicant and her spouse were married (Ex. 1). He had
attended college from 1996 to 2000, in part financed through student loans of $20,000.
He left before finishing his degree (Tr. 70-71), and went to work for an office supply
retailer with the intent of entering an assistant manager’s program (Tr. 34-35).  Three
days after their marriage, Applicant’s spouse was deployed with his reserve unit. He
was called up until about July 2003 (Tr. 37). Applicant stayed in school. She worked that
summer as a junior budget analyst from May 2003 to October 2003 (Ex. 1), but made
no payments toward the credit card debts in SOR ¶¶ 1.h, 1.l, 1.n, 1.p, 1.q, and 1.r that
had been delinquent since 2001/02. In December 2003, one of her credit lenders
obtained a $2,656 judgment against her (SOR ¶ 1.b) (Ex. 4). Applicant appeared in
court with her father and promised to pay the debt (Tr. 98).
In March 2004, Applicant and her spouse had their first child (Ex. 1). His medical
insurance did not cover the full costs of her unexpected cesarean delivery (Tr. 89). A
medical debt of $1,968 was subsequently placed for collection in April 2005 (SOR ¶ 1.d)
(Ex. 4, Tr. 89). Additional medical debts of $109 (SOR ¶ 1.c) $161 (SOR ¶ 1.e) $125
(SOR ¶ 1.f), and $225 (SOR ¶ 1.g) from 2004 were placed for collection (Exs. 3, 4).
Faced with the choice of staying with the office supply retailer in the hope of
becoming a salaried employee or of going on active duty in the military, Applicant’s
spouse enlisted as an active duty soldier in August 2004. He is a light wheel mechanic
(Tr. 123). Ordered to report for active duty in January 2005, he asked for a cash
advance to cover the costs of the family’s relocation. Due to an error, he was paid an
advance of two months’ pay. He assumed the second advance was some type of
entitlement, but discovered that he had to repay the total amount at $336 per month. So
that he could obtain the clearance he needed for his military duties, he focused on
repaying some of his debts, which did not include his student loan debt from 1996 that
due to interest had doubled from its original $20,000 (Tr. 70). Applicant’s delinquent
debts went unpaid (Exs. 3, 4, Tr. 37-38, 40). In November 2004, a collection agency
that had held Applicant’s debt in SOR ¶ 1.l placed the unpaid balance for collection with
This is likely the $1,500 credit card debt Applicant listed on her SF 86 (Ex. 1). The obligee named3
by her on the SF 86 does not appear on either of her credit reports. She testified she had two Visa cards (the
debt in SOR ¶ 1.h and the debt she listed on her SF 86, Tr. 104).
4
the creditor in SOR ¶ 1.m. Another credit card debt of $1,060 (SOR ¶ 1.n) was placed
as well with the same collection agency (Ex. 4).3
In May 2005, Applicant dropped out of college and joined her spouse at his duty
station. She was expecting their second child, and had no earned income. She could
not find a job that would pay her enough to compensate for the cost of daycare (Tr. 115-
16). In September 2005, they had a son (Ex. 1, Tr. 38). Their financial struggles
continued despite his E-5 salary. In 2006, they began to fall behind in their bills.
Applicant’s spouse accepted financial assistance from the Red Cross that he had to
repay at $84 per month for the next two years (Tr. 41-42, 52).
In June 2006, Applicant’s spouse began to make payments of $178 per month to
take his student loans out of forbearance with the intent of eventually finishing his
degree under the military’s education benefit. He made payments for about a year (Tr.
54-56, 70-71). As of January 2009, he owed about $45,000 in student loan debt largely
due to interest (Tr. 59). He was in the process of negotiating with the lender to resume
payments that he could afford so that he can reenroll in college (Tr. 55).
In November 2006, Applicant’s spouse received orders to transfer to the
Northeast (Ex. 1, Tr. 42, 52). He obtained a loan that he used to replace his 1992 Geo
Storm (Ex. 53) with a 2000 Ford Explorer (they also had a 1998 Passat, Tr. 123-24),
and to temporarily move his family to his in-laws’ home in the Midwest. Initially,
repayment of the loan was at $164.99 per month for 36 months, although his monthly
obligation increased to $181.90 in July 2007 after he missed a payment (Ex. B, Tr. 45).
In January or February 2007, he took a cash advance of one month’s pay to cover the
costs of moving his family to their present locale. He had just about paid off his Red
Cross loan (Tr. 44). In April 2007, a medical provider placed an unpaid debt of
Applicant’s for collection in the amount of $469 (Ex. 4).
Applicant’s spouse primarily handled the family’s finances until he was deployed
to Iraq in late March 2008 (Tr. 57-58, 110, 127). While he was in Iraq, she had to spend
$2,300 to repair the Explorer (Tr. 124). In response to DOHA interrogatories inquiring
about her unpaid debt, Applicant explained in June 2008 that she and her spouse had
been paying off his debts over the past year; that since his debts had been paid off in
May 2008, they would be able to concentrate on her debts (Ex. 2).
Following the birth of their third child in 2008, Applicant’s spouse was granted
emergency leave to return to the U.S. in early September 2008. Their infant daughter
was hospitalized for a couple of weeks for treatment of a life-threatening illness (Tr. 59-
61). Since her discharge, they have incurred early intervention costs (clinical
assessments) for their daughter that are not covered by insurance (Tr. 61). 
See footnotes 2 and 3, supra.4
5
Starting in October 2008, Applicant’s spouse has been paid at the E-6 rate. He
was recently released from duty in Iraq (Tr. 64), and his hazardous location pay, hazard
duty pay, and family separation pay ($575 total, Ex. F) will end in February 2009 (Ex.
D). He expects he may have to repay some of those entitlements (Tr. 60).
Applicant and her spouse live on a military installation, so his housing allowance
of $1,765 per month is taken directly out of his pay (Tr. 48-49). Daycare costs of $834
every two weeks and automobile insurance at $122 per month are paid by Applicant out
of her earnings. Her net remainder of about $378 every two weeks goes toward
groceries, gasoline, diapers, formula, and whatever else may be needed in the
household (Tr. 119). Her spouse usually pays the cable television ($140 per month) and
cellular phone costs ($85 per month) (Tr. 50-51) in addition to the $182 loan repayment
(Tr. 109). On occasion, she will give him some of her money if he needs it for
unexpected expenses like car repairs (Tr. 121-22). Neither Applicant nor her spouse
has an active credit card account (Tr. 95, 130). They do not fully agree on how to
handle their financial affairs (Tr. 78, 127). As of her hearing, Applicant had not
contacted any of the creditors listed in the SOR. She planned to pay off her smaller
debts first (Tr. 99-100). As of May 2008, her student loans, which had a balance of
$49,099, were in deferred status (Ex. 3).
Following her hearing, Applicant contacted the creditor that had held those
accounts in SOR ¶¶ 1.p, 1.q, and 1.r. The accounts were no longer in the creditor’s
records and she was advised to dispute them with the credit bureaus. If she is informed
she does not have to repay them, she intends to pursue debt consolidation to resolve
the four larger credit card debts she recognizes (SOR ¶¶ 1.h, 1.i, 1.m and 1.n)  (Ex. D).4
As of the pay period ending December 19, 2008, Applicant’s gross pay for the year
totaled $22,529.10 (Ex. G). Her spouse’s Medicare/security wages for 2008 totaled
$31,818.20. His monthly take home pay for December 2008 was $1,665.39 (Ex. F). On
January 26, 2009, Applicant estimated that she and her spouse had joint monthly
discretionary funds of $766.82 after paying expenses and the $182 monthly loan (Ex.
E).
Applicant has been an “avid volunteer” at the daycare center on base. In 2008,
she was in charge of organizing several important events at the center and she fulfilled
those duties responsibly (Ex. C). A senior acquisitions’ security specialist familiar with
Applicant’s work since March 2007 has found her to be very professional in carrying out
her duties. She is aware that Applicant has financial difficulties and she does not doubt
Applicant’s intention to resolve her debts (Ex. C, Ex. H).
Policies
When evaluating an applicant’s suitability for a security clearance, the
administrative judge must consider the revised adjudicative guidelines (AG). In addition
to brief introductory explanations for each guideline, the adjudicative guidelines list
potentially disqualifying conditions and mitigating conditions, which are useful in
6
evaluating an applicant’s eligibility for access to classified information. These guidelines
are not inflexible rules of law. Instead, recognizing the complexities of human behavior,
these guidelines are applied in conjunction with the factors listed in the adjudicative
process. The administrative judge’s overarching adjudicative goal is a fair, impartial and
common sense decision. According to AG ¶ 2(c), the entire process is a conscientious
scrutiny of a number of variables known as the “whole person concept.” The
administrative judge must consider all available, reliable information about the person,
past and present, favorable and unfavorable, in making a decision.
The protection of the national security is the paramount consideration. AG ¶ 2(b)
requires that “[a]ny doubt concerning personnel being considered for access to
classified information will be resolved in favor of national security.” In reaching this
decision, I have drawn only those conclusions that are reasonable, logical and based on
the evidence contained in the record. Likewise, I have avoided drawing inferences
grounded on mere speculation or conjecture. Under Directive ¶ E3.1.14, the
government must present evidence to establish controverted facts alleged in the SOR.
Under Directive ¶ E3.1.15, the Applicant is responsible for presenting “witnesses and
other evidence to rebut, explain, extenuate, or mitigate facts admitted by applicant or
proven by Department Counsel. . . .” The Applicant has the ultimate burden of
persuasion as to obtaining a favorable security decision.
A person who seeks access to classified information enters into a fiduciary
relationship with the government predicated upon trust and confidence. This relationship
transcends normal duty hours and endures throughout off-duty hours. The government
reposes a high degree of trust and confidence in individuals to whom it grants access to
classified information. Decisions include, by necessity, consideration of the possible risk
that the Applicant may deliberately or inadvertently fail to protect or safeguard classified
information. Such decisions entail a certain degree of legally permissible extrapolation
as to potential, rather than actual, risk of compromise of classified information. Section 7
of Executive Order 10865 provides that decisions shall be “in terms of the national
interest and shall in no sense be a determination as to the loyalty of the applicant
concerned.” See also EO 12968, Section 3.1(b) (listing multiple prerequisites for access
to classified or sensitive information).
Analysis
Guideline F, Financial Considerations
The security concern for financial considerations is set out in AG ¶ 18 of the
adjudicative guidelines:
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.
7
Applicant does not dispute that she incurred delinquent balances on seven credit
card accounts: SOR ¶¶ 1.h and 1.i, two VISA card accounts that are likely those
collection debts in SOR ¶¶ 1.m and 1.n, and SOR ¶¶ 1.p, 1.q, and 1.r. Whether or not
her parents incurred the debt in SOR ¶ 1.b, she is legally responsible for the judgment
balance as well since the account was in her name. She appeared in court with her
father and promised to pay the debt with his assistance but did not do so (Tr. 98).
Applicant also admits unpaid medical debt totaling about $3,057 (SOR ¶¶ 1.c, 1.d, 1.e,
1.f, 1.g, and 1.r). As of January 2009, those debts, totaling about $14,000, had not been
paid. Significant security concerns are raised by “inability or unwillingness to satisfy
debts” (AG ¶ 19(a)) and by “a history of not meeting financial obligations” (AG ¶ 19(c)).
The government did not meet its burden of proving that Applicant owed the
additional $4,854 in disputed debt alleged in SOR ¶¶ 1.a, 1.j, 1.k, 1.l, and 1.o. As noted
in footnote 2, supra, although the amounts differ, the debts in SOR ¶¶ 1.a and 1.l are
likely the same debt as the collection debt in SOR ¶ 1.m. Applicant did not recognize
any debt to the creditor in SOR ¶ 1.k or the medical debt in SOR ¶ 1.j. She
acknowledged having had cellular phone service in college with the creditor that had
referred a $224 debt for collection (SOR ¶ 1.o), but she denied any knowledge of an
outstanding balance. The debts alleged in SOR ¶¶ 1.j, 1.k, and 1.o are not included on
her more recent June 2008 credit report (Ex. 3). However, 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,” does not mitigate the $14,000 in
proven debt.
Applicant’s credit card accounts became delinquent over the 2001/02 time frame,
when she was unmarried, attending college, and working at minimum wages. Yet, 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,” cannot be fully applied in
mitigation because of her more recent delinquent medical debt, including the $1,968
hospital bill incurred in the birth of her first child, and the fact that her debts have yet to
be resolved.
AG ¶ 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,” is implicated. The loss of her student
research employment, the significant drop in financial assistance from her parents after
her father lost his job in 2001, the low wages paid her when she was employed while in
school from 2001 to 2005, insufficient medical insurance to cover an unexpected C-
section in March 2004, and her inability to find a job that would pay her enough to cover
daycare costs at her spouse’s first active duty station, are all factors outside of her
control that led to the delinquencies and then her failure to resolve the debts in a timely
manner.
Applicant’s financial situation cannot fairly be evaluated without taking into account her spouse’s5
income and his debt obligations, as they affect her finances. Daycare costs ($1,668 per month), which she
covers, amount to more than half of her monthly take-home pay ($1,349.68 every two weeks).
8
For AG ¶ 20(b) to fully apply, Applicant must have acted responsibly to address
her debts once she was in a position to do so. Applicant did not work outside of the
home and the family needed a loan from the Red Cross to pay their bills in 2006. At the
same time, her spouse began repaying his student loan in June 2006 in an effort to
bring it out of forbearance so that he could return to school. Any available funds during
that time also went to pay off some of her spouse’s debt so that he could obtain the
security clearance he needed for the military. Even after Applicant began working in
March 2007, she did not have the funds to devote to her old debts.
In response to DOHA interrogatories, Applicant indicated in June 2008 that they
had paid off her spouse’s debt and would be able to concentrate on her delinquent
accounts. She had not contacted her creditors before her hearing in January 2009, but
her spouse’s deployment, the birth of their third child that summer, and then her
newborn’s life-threatening illness, are significant extenuating factors. Although she
probably could have paid the smaller medical debts in SOR ¶¶ 1.c, 1.e, and 1.f,  AG ¶
20(b) applies in part.
Before the record closed, Applicant provided a statement indicating she had
contacted one lender in an effort to make payments on the debts in SOR ¶¶ 1.p. 1.q,
and 1.r. On the advice of the creditor, who was unable to confirm any outstanding
balances, Applicant disputed them with Trans Union. Assuming she will not be required
to repay those debts, her debt burden would be reduced by only $898. While these
efforts post-hearing to address her indebtedness are not enough in and of themselves
to qualify for mitigation under 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 is under control,” or AG ¶ 20(d), “the individual initiated a good-faith effort to
repay overdue creditors or otherwise resolve debts,” the evidence warrants partial
application of AG ¶¶ 20(c) and 20(d) taking the household as a whole.  Applicant’s5
spouse, who  handled repayment of old debt obligations until he went to Iraq, focused
on repaying his debts first. His debts have been resolved with the exception of his
student loans. Applicant and her spouse have yet to fully agree as to how to handle
some of their financial obligations, but they do not rely on consumer credit and there is
no evidence of extravagant expenditure.
Whole-Person Concept
Under the whole-person concept, the administrative judge must evaluate an
applicant’s eligibility for a security clearance by considering the totality of the conduct
and all the circumstances in light of the nine adjudicative process factors listed at AG ¶
2(a):
(1) the nature, extent, and seriousness of the conduct; (2) the
circumstances surrounding the conduct, to include knowledgeable
9
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
which 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.
Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a security
clearance must be an overall commonsense judgment based upon careful consideration
of the guidelines and the whole-person concept.
The DOHA Appeal Board has addressed a key element in the whole person
analysis in financial cases stating:
In evaluating Guideline F cases, the Board has previously noted that the
concept of “‘meaningful track record’ necessarily includes evidence of
actual debt reduction through payment of debts.” However, an applicant is
not required, as a matter of law, to establish that he has paid off each and
every debt listed in the SOR. All that is required is that an applicant
demonstrate that he has ‘ . . . established a plan to resolve his financial
problems and taken significant actions to implement that plan.’ The Judge
can reasonably consider the entirety of an applicant’s financial situation
and his actions in evaluating the extent to which that applicant’s plan for
the reduction of his outstanding indebtedness is credible and realistic. See
Directive ¶  E2.2(a) (‘Available, reliable information about the person, past
and present, favorable and unfavorable, should be considered in reaching
a determination.’) There is no requirement that a plan provide for
payments on all outstanding debts simultaneously. Rather, a reasonable
plan (and concomitant conduct) may provide for the payment of such
debts one at a time. Likewise, there is no requirement that the first debts
actually paid in furtherance of a reasonable debt plan be the ones listed in
the SOR.
ISCR Case No. 07-06482 at 2-3 (App. Bd. May 21, 2008) (internal citations omitted).
Applicant has “a meaningful track record” of paying her current financial obligations, and
she has a credible and realistic plan to pay her delinquent debt.
Applicant candidly acknowledged the existence of delinquent debt, including
consumer credit obligations incurred when she was in college. Her failure to repay this
debt to date was reasonably explained, however. Despite full time employment since
March 2007, most of her income has gone to child care, car insurance, and essential
expenses for the care of their children. Applicant needed her spouse’s agreement and
financial assistance to resolve her old debts, and he was focused on his old debts. They
could ill afford jeopardizing his clearance by ignoring the debt he brought into the
marriage or incurred in moving the family for his military career. While she had some
control over their finances following his deployment to Iraq in March 2008, she incurred
$2,300 in unexpected auto repair expenses. Although she indicated in June 2008 that
10
they could begin to repay her debts, she had the day-to-day responsibilities of a single
parent caring for two preschool age children and then a newborn who became ill with a
life-threatening illness. Her spouse returned from Iraq in early September 2008, but they
were understandably focused on their daughter.
As of her hearing in January 2009, Applicant’s spouse had been released from
further duty in Iraq, and their infant had recovered sufficiently to attend daycare.
Certainly, Applicant would have had a stronger case in mitigation had she started
repaying her delinquent debts. However, she expressed a credible plan to pay off her
smaller debts first and then obtain a consolidation loan to resolve the others. Before the
record closed in this case, she contacted the lender who had extended credit to her on
the smaller accounts that she planned to pay off first. She is unlikely to have contacted
the lender unless she planned to repay the debts. The corporate security manager who
handled Applicant’s request for clearance with their previous employer does not doubt
Applicant’s intent to resolve her old debts. The concerted efforts by Applicant and her
spouse to satisfy his delinquent debts and to live within their means indicate that they
both understand the importance of addressing her debt as well.
Formal Findings
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: FOR APPLICANT
Subparagraph 1.a: For Applicant (Duplication of ¶ 1.m)
Subparagraph 1.b: For Applicant
Subparagraph 1.c: For Applicant
Subparagraph 1.d: For Applicant
Subparagraph 1.e: For Applicant 
Subparagraph 1.f: For Applicant
Subparagraph 1.g: For Applicant
Subparagraph 1.h: For Applicant
Subparagraph 1.i: For Applicant
Subparagraph 1.j: For Applicant
Subparagraph 1.k: For Applicant 
Subparagraph 1.l: For Applicant (Duplication of ¶ 1.m)
Subparagraph 1.m: For Applicant
Subparagraph 1.n: For Applicant
Subparagraph 1.o: For Applicant
Subparagraph 1.p: For Applicant
Subparagraph 1.q: For Applicant
Subparagraph 1.r: For Applicant
Subparagraph 1.s: For Applicant
Conclusion
11
In light of the record in this case, it is clearly consistent with the national interest
to grant Applicant eligibility for a security clearance. Eligibility for access to classified
information is granted.
ELIZABETH M. MATCHINSKI
Administrative Judge