DEPARTMENT OF DEFENSE 
  DEFENSE OFFICE OF HEARINGS AND APPEALS 
  
  
 
 
In the matter of: ) 
 ) 
  )  ISCR Case No. 09-07818 
  ) 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: David F. Hayes, Esquire, Department Counsel 
For Applicant: Pro se 
 
 
 
 
______________ 
 
Decision 
______________ 
 
 
HEINY, Claude R., Administrative Judge: 
 
 
Applicant has failed to rebut or mitigate the financial considerations security 
concerns. Clearance is denied. 
 
 
Statement of the Case 
 
 Applicant contests the Department of Defense’s (DoD) intent to deny or revoke 
her eligibility for an industrial security clearance. Acting under the relevant Executive 
Order and DoD Directive,1 the Defense Office of Hearings and Appeals (DOHA) issued 
                                                          
1 Executive Order 10865, Safeguarding Classified Information within Industry (February 20, 
1960), as amended; Department of Defense (DoD) Directive 5220.6, Defense Industrial Personnel 
Security Clearance Review Program (January 2, 1992), as amended (Directive), and the adjudicative 
guidelines (AG) effective within the DoD on September 1, 2006. 
 
1 
a Statement of Reasons (SOR) on May 4, 2010, detailing security concerns under 
financial considerations. 
  
 On June 16, 2010, Applicant answered the SOR and elected to have the matter 
decided without a hearing. Department Counsel submitted the Government's case in a 
File of Relevant Material (FORM), dated September 3, 2010. The FORM contained ten 
attachments. On September 17, 2010, Applicant received a copy of the FORM, along 
with notice of her opportunity to file objections and submit material to refute, extenuate, 
or mitigate the potentially disqualifying conditions.  
 
On October 18, 2010 and December 21, 2010, Applicant responded to the 
FORM. Department Counsel did not object to the material, which was admitted as 
Exhibits (Ex. A – Q). Applicant's responses were admitted into the record. On October 
28, 2010, I was assigned the case.  
 
Findings of Fact 
 
In Applicant’s Answer to the SOR, Applicant admitted owing 23 debts and denies 
owing 16 debts. I incorporate Applicant’s admissions to the SOR allegations. After a 
thorough review of the record, pleadings, and exhibits, I make the following findings of 
fact. 
 
 Applicant is a 29-year-old risk management analyst and engineer who has 
worked for a defense contractor since June 2009, and is seeking to obtain a security 
clearance. In her May 2010 evaluation, her supervisor states Applicant has 
demonstrated a proactive spirit and has developed a very favorable reputation with the 
government customer. Her job performance ratings or the period were “exceeds 
expectations” and “outstanding.” (Item 4, Ex. E) She is a single mother of one.  
 
 From January 2001 to June 2002, Applicant was unemployed. (Item 5) From 
January 2001 to December 2004, Applicant attended state university and obtained a 
bachelor’s degree in electronics engineering in December 2004. From January 2006 to 
August 2009, Applicant attended state university in the position of project administrator. 
Applicant had a number of jobs while attending school.  
 
In August 2009, Applicant completed an Electronic Questionnaires for 
Investigations Processing (e-QIP). (Item 5) Numerous creditors were listed in her 
response to the financial inquires on her e-QIP. In March 2010, in response to written 
interrogatories, she indicated she was paying $300 monthly on her debts. (Item 6)  
 
Applicant asserts she hired a credit counseling company to help her with her 
financial problems. In December 2009, Applicant went to a credit service to seek help in 
restoring her credit. On December 14, 2009, she paid the service $99. (Item 6) She 
made a similar payment in January 2010. She provided no documentation as to what 
services the company had provided or was to provide. On December 20, 2010, 
Applicant submitted a letter from a law firm she appears to have employed to help her 
 
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with her financial problems. (Ex. N) From the letter it appears Applicant had just recently 
employed the firm. There is no documentation showing what services the firm was to 
provide. This is not the same financial assistance company that she previously 
employed.  
 
As of March 2010, Applicant’s monthly gross income was $5,773 and her 
monthly net remainder was $1,315. Her monthly debts, which she was paying, included: 
$300 on her student loans, $650 car payment, $80 credit card payment, $130 
orthodontist, and $75 for the credit service. Her current salary is $80,000 per year. (Ex. 
A) 
 
 On June 16, 2010, Applicant stated she intended to have all her debt paid in full 
within seven months. Applicant asserts her financial problems began in 2006 when she 
was involved in a vehicle accident and difficult pregnancy. As a part-time employee, she 
did not have health insurance to cover her medical expenses. Applicant also suffers 
from a hypo thyroid condition. She asserted that medical debt accounted for the majority 
of the debt. She also asserted she had contacted all of the creditors and arranged 
repayment plans and the debts were being paid by automatic deductions from her 
checking account. (Item 1) 
 
 In Applicant’s September 2009 personal subject interview (Item 6), she was 
aware of the ten of her medical debts listed in her credit bureau report (CBR). They had 
been consolidated and were being collected by a single collection agency. Those 
accounts are: $78, $21, $52, $179, $197, $522, $207, $243, $1,184 and $148 (SOR ¶¶ 
1. q, 1.t – 1.y, 1.ae, and 1af). In March 2010, she again acknowledged these amounts 
appear on her CBR, however she had no information about the accounts.  
 
 Applicant incurred a $1,244 power and electric utility bill, which in March 2010 
the creditor agreed to settle for $622, Bi weekly payments were to start in March 2010 
and end in July 2010. (Item 6, Ex. G) An August 2010 letter from the creditor indicates a 
zero balance on this debt. (Ex. M)  
 
 In April 2010, Applicant asserts she started making $40 monthly payments on a 
$420 balance for the three medical accounts listed in SOR ¶¶ 1.w ($522), 1.x ($197), 
and 1. y ($179). (Item 6, Ex. H) Applicant asserted, but failed to document, she had paid 
off $600 in medical debts for the debts in: SOR ¶¶ 1.b ($332), 1.ai ($174), and 1. aj 
($50). (Ex. A and Ex. D) 
 
 Applicant also asserted she was making monthly payments to four other 
creditors. She asserts she is making $50 monthly payments on the debt listed in SOR ¶ 
1.a ($1,509). She furnished five letters from the creditor reminding her $25 would be 
debited from her account on September 24, 2010, October 8, 2010, November 5, 2010, 
November 19, 2010, and, December 3, 2010. (Ex. L and Ex. P) The reminder letters do 
not list the balance of this account.  
 
 
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 On March 18, 2010, the creditor (SOR ¶ 1.aa, $542) offered to settle the debt for 
$628 with payments of $104. (Item 6, Ex. I) She provided no documentation showing 
payment. She asserts will be paid in full by November 2010.  
 
 In September 2010, Applicant agreed to allow the creditor to make four $70 
debits from her account. Debits would occur every two weeks between October 8, 2010 
and November 19, 2010. (FORM Answer) In her FORM Answer, she asserted she was 
making $141 monthly payment on this debt (SOR ¶¶ 1. z, $673). As of November 12, 
2010, the balance had been reduced to $495. (Ex. O) 
 
 Applicant asserts she had arranged a repayment plan with the collection agency 
holding four medical treatment debts (SOR ¶ 1.b, $332; 1.d, $85; 1.e, $172; 1.f, $50). 
She asserted, but failed to document, she was paying the creditor $20 monthly. (Item 6) 
She said the creditor would not provide documentation until the first payment was 
received. (Item 6) 
 
 Applicant included a creditor’s letter dated November 12, 2010, indicating a 
postdated check or preauthorized payment in the amount of $25 would be processed on 
November 19, 2010. The balance due was $75. (Ex. Q) The creditor is not listed in the 
SOR and Applicant gives no indication which accounts are being handled by this 
payment. In her March 2010 response to written interrogatories (Item 6) she indicates 
she was making a $20 payment every two weeks on three debts (SOR ¶¶ 1.g, $47; 1.h. 
$136; and 1.i, $204). The creditor listed does not have the same name as the creditor 
listed in the November 12, 2010 letter.  
 
 In Applicant’s Ex. K, she asserted she was paying $25 twice monthly for a total of 
$50 per month to a creditor. However, that creditor’s name is not listed for any of the 
SOR debts and she failed to indicate which debt or debts this payment was to cover. 
She also asserted she had three other repayment plans, but the creditors would not 
provide any information until the debts were paid in full. She failed to indicate which 
debts were covered by these three agreements and failed to show payment to the three 
creditors. She pays $14 monthly to have access to view her CBRs and to receive credit 
alerts. (Ex. A)  
 
 Applicant and her ex-boyfriend purchased joint two-year gym memberships that 
resulted in two accounts being placed for collection (SOR ¶¶ 1.al, $3,202 and 1.am, 
$786). She stopped attending the gym. (Item 6) In her September 2009 personal 
subject interview, she said she had contacted the creditor and intended to pay $123 
monthly on the debt. In March 2010, she said she was disputing the gym membership, 
but gave no reasons for so doing and provided no documentation related to the dispute. 
In June 2010, she said she was working on a settlement. (Item 4) 
 
 The three CBRs list 13 medical accounts (SOR ¶¶ 1.j, $32; 1.k, $39; 1.n, $106; 
1.o, $44; 1.q, $78; 1.t, $148; 1.u, $243; 1.v, 4207; 1.w, $522; 1.x, $197, 1.y, $197; 1.ae, 
$21; and, 1.af, $1,184), which total $3,000. (Items 8, 9, 10) For these accounts the 
CBRs fail to provide a name, telephone number, address, or other method of contacting 
 
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the creditor or verifying the account. Applicant disputed these medical accounts 
because there was no creditor or company information available on the CBR and no 
proof they were her accounts. Applicant denied owing these debts in her SOR Answer. 
(Item 4)  
 
 Although initially denying three of the medical accounts listed in her CBRs 
because they lacked additional identifying information, Applicant asserted she is making 
$40 monthly payments on the debts listed in SOR ¶ 1.w ($522), ¶ 1.x ($197), and ¶ 1.y 
($197).  
 
 The FORM placed Applicant on notice that she had to provide documentation 
supporting her assertions she had paid accounts, was making payment on accounts, 
had established repayment agreements with creditors, had received financial 
counseling, or provide clear indications that her financial problems were being solved or 
were under control. As previously noted, documentation was not received for numerous 
accounts. 
 
 A summary of Applicant’s judgment, accounts charged off, accounts placed for 
collection, and other unpaid obligations and their current status follows: 
 
 Creditor Amount  Current Status 
a Bank account placed for 
collection. 
$1,509 Paying. The creditor sent her five letters 
reminding her that $25 would be 
debited from her account as agreed. 
(Ex. L and Ex. P) 
b Account placed for 
collection. 
$332 
 
No documents. Applicant asserted, but 
failed to document, she was making 
payment on this debt. She said 
collection agency had consolidated four 
accounts on which she was making $20 
monthly payments. She said the 
creditor would not provide 
documentation until the first payment 
was received. (Item 6, Ex. A, and Ex. D)
c Account placed for 
collection. 
 
$791 
 
No documents. Applicant asserted, but 
failed to document, she had arranged a 
repayment plan on this debt. (Item 4)  
d Account placed for 
collection. 
$85 No documents. Same collection firm as 
b. above.  
e Account placed for 
collection. 
$172 No documents. Same collection firm as 
b. above. 
 
 
 
5 
 
 Creditor Amount  Current Status 
f Account placed for 
collection. 
$50 No documents. Same collection firm as 
b. above. 
g Account placed for 
collection. 
$47 No documents. She asserted, but 
failed to document, she was making 
$20 payments on his debt every two 
weeks. (Item 6)  
h Account placed for 
collection. 
$136 No documents. Same collection firm as 
g. above. 
 i Account placed for 
collection. 
$204 No documents. Same collection firm as 
g. above. 
j  Unpaid medical account. $32 Disputes. Applicant disputes because 
the CBR contain no information 
identifying the creditor. (Item 3) 
k Unpaid medical account. $39 Disputes. See j. above.  
l Cable account placed for 
collection. 
$324 
 
Duplication. Applicant contacted the 
creditor and only the account listed in 
m. could be located.  
m Cable account placed for 
collection. 
$408 
 
No documents. Unpaid. Applicant 
asserted, but failed to document, she 
was disputing this debt. (Item 4)  
n Unpaid medical account. $106 Disputes. See j. above. 
o Unpaid medical account. $44 Disputes. See j. above. 
p Account placed for 
colletion. 
$705 
 
No documents. Applicant asserted, but 
failed to document, she had arranged a 
repayment plan on this debt. (Item 4) 
q Unpaid medical account. $78 Disputes. See j. above. 
r Account placed for 
collection. 
$577 
 
Unpaid.  
s Power and electric utility 
account placed for 
collection. 
$1,244 
 
Paid. The creditor offered to settle the 
matter for $622. (Item 6) In August 
2010, the creditor states there was a 
zero balance on this account. (Ex. G 
and M)  
 
 
 
6 
 Creditor Amount  Current Status 
t Unpaid medical account. $148 Disputes. See j. above. 
u Unpaid medical account. $243 Disputes. See j. above. 
v Unpaid medical account. $207 Disputes. See j. above. 
w Unpaid medical account. $522 No documents. Applicant asserted, but 
failed to document, that in April 2010 
she began to make $40 monthly 
payments on this debt. A single creditor 
is collecting this debt and the debts 
listed in SOR ¶¶ 1.x and 1.y. (Item 6, 
Ex. A, and Ex. H) 
x Unpaid medical account. $197 No documents. See w. above. 
y Unpaid medical account. $179 No documents. See w. above. 
z Credit card account 
placed for collection.  
 
$673 
 
Paying. In September 2010, Applicant 
agreed to allow the creditor to make four 
$70 debits from her account. Debits 
would occur every two weeks. As of 
November 12, 2010, the balance due 
had been reduced to $495.49. (Ex. B, 
Ex. C, and Ex. O)  
aa Account charged off.  
 
$542 
 
No documents. On March 18, 2010, the 
creditor offered to settle the debt for 
$628 and accepting monthly payments 
of $104. (Item 6 and Ex. I) She provided 
no documents showing payment on the 
offer. 
ab Judgment filed in January 
2007. 
$110 
 
No documents. Medical treatment debt 
incurred during her pregnancy. She 
asserts, but failed to document, she 
paid this debt. (Item 6)  
ac Telephone service 
account placed for 
collection. 
$713 Unpaid. This was for telephone service 
her mother put in Applicant’s name 
without telling her. (Item 6) Her mother 
failed to pay the bill. Applicant asserts 
the creditor offered to settle the debt for 
$215.  
ad Account placed for 
collection. 
$331 No documents. Same collection firm as 
b. above.  
 
 
7 
 
8 
 Creditor Amount  Current Status 
ae Unpaid medical account. $21 No documents. Applicant asserted, but 
failed to document, she had arranged a 
repayment plan on this debt. (Item 4) 
 af Unpaid medical account. $1,184 Disputes. See j. above. 
ag Medical account placed 
for collection. 
$187 
 
Unpaid. No documents. Applicant 
asserted, but failed to document, she 
was making payment on this debt. (Item 
4)  
ah Bank account placed for 
collection.  
$531 Unpaid. Applicant admits she owes the 
account, but was unable to pay it. (Item 
4) 
ai Account placed for 
collection. 
$174 No documents. Applicant asserted, but 
failed to document, she had paid this 
debt. (FORM Answer)  
aj Account placed for 
collection. 
$50 No documents. Applicant asserted, but 
failed to document, she had paid this 
debt. (FORM Answer, Item 4, Ex. A, and 
Ex. D) 
ak Insurance account placed 
for collection. 
$118 Unpaid. She said she would pay the 
debt in July 2010. No documentation of 
payment has been received. (Item 4) 
al Gym membership 
account placed for 
collection.  
$3,202 Unpaid. In June 2010 she said she was 
working on a settlement. (Item 4) 
am Gym membership 
account placed for 
collection.  
$786 Unpaid. In June 2010 she said she was 
working on a settlement. (Item 4) 
 Total debt listed in SOR $17,001  
 
Policies 
 
 When evaluating an applicant’s suitability for a security clearance, the 
administrative judge must consider the adjudicative guidelines. In addition to brief 
introductory explanations for each guideline, the adjudicative guidelines list potentially 
disqualifying conditions and mitigating conditions, which must be considered in 
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 commonsense 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. 
 
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 to obtain 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 the applicant may deliberately or inadvertently fail to safeguard 
classified information. Such decisions entail a certain degree of legally permissible 
extrapolation of 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 of 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 
 
 Adjudicative Guideline (AG) ¶18 articulates the security concerns relating to 
financial problems: 
 
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 
 
9 
overextended is at risk of having to engage in illegal acts to generate 
funds. 
 
An individual who is financially irresponsible may also be irresponsible, 
unconcerned, negligent, or careless in properly handling and safeguarding classified 
information. Behavior in one aspect of life provides an indication of how a person may 
behave in other aspects of life.  
 
A person’s relationship with her creditors is a private matter until evidence is 
uncovered demonstrating an inability or unwillingness to repay debts as agreed. Absent 
substantial evidence of extenuating or mitigating circumstances, an applicant with a 
history of serious or recurring financial difficulties is in a position of risk that is 
inconsistent with holding a security clearance. An applicant is not required to be debt 
free, but is required to manage her finances to meet her financial obligations. 
 
 Applicant has a history of financial problems. The SOR lists 39 delinquent 
accounts. Applicant has one judgment, 13 unpaid accounts, 24 accounts placed for 
collection, and one account charged off, which totaled approximately $17,000. Nine of 
Applicant’s debts were under $100 each. Another seven were $150 or less, and an 
additional ten were $500 or less. The evidence supports application of disqualifying 
conditions AG ¶19 (a), “inability or unwillingness to satisfy debts” and AG ¶19 (c), “a 
history of not meeting financial obligations,” apply.  
 
 Five Financial Considerations Mitigating Conditions under AG ¶ 20 are potentially 
applicable: 
 
(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; 
 
(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; 
 
(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; 
 
(d) the individual initiated a good-faith effort to repay overdue creditors or 
otherwise resolve debts; and 
 
(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 
 
10 
documented proof to substantiate the basis of the dispute or provides 
evidence of actions to resolve the issue. 
 
Because Applicant has multiple delinquent debts and her financial problems are 
continuing in nature, she receives minimal application of the mitigating conditions listed 
in AG ¶ 20(a). Applicant’s handling of her finances, under the circumstances, casts 
doubt on her current reliability, trustworthiness, or good judgment.  
 
There is no evidence Applicant has received financial counseling. She asserts 
she hired a credit company to help her with her financial problems and help in restoring 
her credit. No documentation was received as to the services the company had 
provided or was to provide. The amount of remaining debt must be considered in 
determining the amount of benefit Applicant received from the credit company. 
 
Applicant has paid or is paying three of the SOR debts (SOR ¶ 1 a, $1,509; SOR 
¶ 1 s, $1,244; and SOR ¶ 1 z, $673) which total $3,426. The mitigating conditions listed 
in &20(d) apply to these three debts. Applicant contacted the collection agency 
collecting the debts listed in SOR ¶ 1.l ($324) and SOR ¶ 1.m ($408), which both related 
to the same cable company. The collection agency had only one of the accounts placed 
for collection. I find the cable account listed in SOR ¶ 1.l is a duplicate of the debt listed 
in SOR ¶ 1.m. 
 
Applicant asserted she had arranged repayment plans with 16 additional 
accounts, but failed to provide documents to support her assertion. Merely stating a 
debt was paid or that a repayment plan has been established is insufficient. Promises of 
payment without actual payment are common. Additionally, she has not shown 
payments in accordance with the repayment plans. Without a history showing actual 
payments having been made, I can not find she has made a “good-faith2” effort to repay 
overdue creditors or otherwise resolve debt. The mitigating conditions in &20.(d) do not 
apply to these 16 debts.  
 
Applicant asserts she disputes nine additional accounts placed for collection 
which total approximately $2,000. For the mitigating conditions in AG ¶ 20.(e) to apply 
not only must an applicant a dispute the obligation, but they must provide documented 
proof to substantiate the basis of the dispute or provide evidence of actions to resolve 
                                                          
2 The Appeal Board has previously explained what constitutes a “good-faith” effort to resolve debts: 
 
In order to qualify for application of [the “good-faith” mitigating condition], an applicant 
must present evidence showing either a good-faith effort to repay overdue creditors or 
some other good-faith action aimed at resolving the applicant’s debts. The Directive does 
not define the term ‘good-faith.’ However, the Board has indicated that the concept of 
good-faith ‘requires a showing that a person acts in a way that shows reasonableness, 
prudence, honesty, and adherence to duty or obligation.’ Accordingly, an applicant must 
do more than merely show that he or she relied on a legally available option (such as 
bankruptcy) in order to claim the benefit of [the “good-faith” mitigating condition].  
 
(internal citation and footnote omitted) ISCR Case No. 02-30304 at 3 (App. Bd. Apr. 20, 2004) (quoting 
ISCR Case No. 99-9020 at 5-6 (App. Bd. June 4, 2001)) 
 
11 
the issue. She failed to provide documentation for these nine accounts placed for 
collection.  
 
The mitigating factors listed under AG ¶ 20.(b) only partly apply. She was 
unemployed form January 2001 through June 2002. In 2006, she was involved in an 
automobile accident and had a difficult pregnancy. These are factors beyond her 
control. In 2009, her current employment began and her monthly net remainder has 
been $1,300 with which she could have addressed her debts. She asserted, but failed 
to document, she is paying her bills. Without such documentation, I can not find she has 
acted responsibly under the circumstances.  
 
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 applicant’s 
conduct and all relevant circumstances. The administrative judge should consider 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 
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.  
 
I considered the potentially disqualifying and mitigating conditions in light of all 
the facts and circumstances surrounding this case. About $3,300 of the debt, which is 
about 20 percent of the total debt, related to medical bills. Medical bills are not financial 
obligations that indicate poor self-control, lack of judgment, or unwillingness to abide by 
rules and regulations, and do not reflect money spent frivolously. However, 80 percent 
of Applicant’s debt represents non-medical debt. Since being hired, Applicant has had 
more than $1,000 per month in net disposable income, which could have been applied 
to her debts. She asserted she has made arrangements with her creditors and is 
repaying her debts. However, there is no documentation showing the repayment plans 
or monthly payment in compliance with the plans.  
 
In requesting an administrative determination, Applicant chose to rely on the 
written record. In so doing, however, she failed to submit sufficient information or 
evidence to supplement the record with relevant and material facts regarding her 
circumstances, articulate her position, and mitigate the financial security concerns. She 
 
12 
 
13 
failed to offer sufficient evidence of financial counseling or provide documentation 
regarding her past efforts to address her delinquent debt. By failing to provide such 
information, financial considerations security concerns remain. Clearance is denied.  
 
Formal Findings 
 
 Formal findings for or against Applicant on the allegations set forth in the SOR, 
as required by section E3.1.25 of Enclosure 3 of the Directive, are: 
 
 Paragraph 1, Financial Considerations: AGAINST APPLICANT 
 
  Subparagraph 1.a:   For Applicant 
  Subparagraphs 1.b–1.r:   Against Applicant 
  Subparagraph 1.s:   For Applicant 
  Subparagraphs 1.t–1.y:  Against Applicant 
  Subparagraph 1.z:   For Applicant 
  Subparagraphs 1.aa–1.am: Against Applicant  
 
 
Conclusion 
 
 In light of all of the circumstances presented by the record in this case, it is not 
clearly consistent with the national interest to grant Applicant eligibility for a security 
clearance. Eligibility for access to classified information is denied.  
 
 
 
_____________________ 
CLAUDE R. HEINY II 
Administrative Judge