1
                                                             
                           
                        DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
--------------------- )       ISCR Case No. 09-04975
)
Applicant for Security Clearance )
Appearances
For Government: Kathryn D. MacKinnon, Esquire, Department Counsel
For Applicant: Pro se
                                                                            
______________
Decision
______________
MARSHALL, Jr., Arthur E., Administrative Judge:
On April 30, 2010, the Defense Office of Hearings and Appeals (DOHA) issued a
Statement of Reasons (SOR) enumerating security concerns arising under Guideline F
(Financial Considerations). DOHA took action under 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. 
In a response dated May 26, 2010, Applicant answered the five allegations
raised in the SOR under Guideline F and provided supplemental explanations
concerning each allegation. He also requested a hearing before a DOHA administrative
judge. DOHA assigned the case to me on October 7, 2010. The parties proposed a
hearing date of December 6, 2010. A notice setting that date for the hearing was issued
on November 16, 2010. I convened the hearing as scheduled. 
Applicant gave testimony, introduced one witness, and offered 12 documents,
which were accepted into the record without objection as exhibits (Ex.) A-L. He was
given until January 4, 2011, to submit any additional documents. The Government
introduced five documents, which were accepted into the record without objection as
 Tr. 16.      1
 Tr. 47-48. As noted by the Government, he “did [his] due diligence to the best of his ability.” The house      2
was an approximately 1,300 square foot property. Tr. 49.
 Tr. 17.      3
 Tr. 47.      4
 Id.      5
2
Exs. 1-5. The transcript (Tr.) of the proceeding was received on December 14, 2010.
On December 21, 2010, Department Counsel forwarded to me four additional
documents, which were accepted into the record without objection as Exs. M-P. On
January 4, 2011, when no further submissions were received, the record was closed.
Based on a review of the testimony, submissions, and exhibits, I find Applicant met his
burden of mitigating security concerns related to financial considerations. Clearance is
granted.
Findings of Fact
Applicant is a 39-year-old senior network engineer who has worked for the same
government contractor for three years. He earned a high school diploma and has
attended some college-level studies. He is divorced and has two teenaged children. 
In 1992, Applicant and his ex-wife married. Between 2001 and 2002, Applicant
and his former spouse experienced marital difficulties. They separated during this
period, ultimately divorcing in 2008. In the interim, she moved with their children to a
distant state. Applicant soon followed them in order to maintain his relationship with his
young children. He sold their house and bought a second home in the new state, where
he assumed physical custody of the children.  After about six to eight months, his1
estranged wife returned north to their original state of residence. Applicant and his
children enjoyed a period of stability for the rest of the school year and through that
summer. Shortly after the new school year began, his wife returned and took their
children home with her. 
After consulting a real estate management company and concluding it would not
be difficult to rent the modestly sized house, Applicant quickly found renters for the
house and followed his children back to their former area of residence in 2003.  During2
his absence, he routinely checked with the property managers once a month. Between
2003 and 2004, he took an equity loan from the house and quickly purchased a modest
townhouse in the same state where his children now resided in order to offer his
children more stability.  With the prospect of living with or near his children being a3
paramount concern, he did not vigorously investigate his new neighborhood, which was
located in a rural area.  Unbeknownst to Applicant, the townhouse he chose was4
located in an area with rising crime. By 2005, the value of the townhouse began to
decline due to a souring real estate market.  5
 Tr. 18.       6
 Id. See also Tr. 49.      7
 Tr. 55-56.      8
 Tr. 106.      9
 Tr. 92.      10
 Tr. 51, 84.      11
 Tr. 52-53. Given his prior problems with a management company, Applicant scrutinized potential tenants      12
closely.
 Tr. 73.      13
3
Despite a management clause prohibiting sublets, the rented house was then
sublet to “15 illegal immigrants” who, by about 2007, “destroyed it.”  Applicant learned6
of this situation from neighbors, not the management company. He quickly returned to
his former residence to “re-do everything in the sense of inside the house and get it
back to renting again.”  New renters were subsequently found about six to eight months7
later. During that time and throughout, Applicant made timely payments on that
property’s mortgage. With new property managers, it has housed reliable tenants since
that time.  8
Not long after Applicant returned to his townhouse, his estranged wife sued for
child support, despite their prior agreement to work their financial issues out informally.
He was also told she would keep the children in her physical care. 
Shortly thereafter, Applicant was offered his current position and met a girlfriend.
He found roommates to help offset his mortgage payments on his townhouse
residence.  Because of escalating crime in his neighborhood, including nearby murders,9
however, he determined his home was no longer safe for him and his children. Around
this time, he assumed full custody of his oldest child. While the townhouse remained as
his legal residence, he temporarily rented a cabin in a safe area in which he and one
son could live.  They then moved in with his girlfriend, where Applicant and his10
girlfriend shared expenses for her larger home. While this arrangement served their
safety needs, the added expense of paying for a third home became burdensome.
In about 2008, Applicant tried unsuccessfully to refinance his townhouse as a
way to offset the increased funds necessary to maintain a safe household elsewhere.11
He then unsuccessfully tried to find reliable tenants for the townhouse while applying for
a home loan modification.  He hoped that a reliable tenant’s rent could help off-set his12
need to continue paying his full mortgage payments on the property.  In 2009, he13
sought a loan modification. With no success finding tenants or working with his lenders,
Applicant realized he could no longer meet his obligations on the out-of-state property,
make payments on the empty townhouse at the then-present mortgage rate, and
 Tr. 85-86.      14
 Tr. 89.      15
 Tr. 61.      16
 Tr. 62-63.      17
 Ex. M (Lender letter, dated Dec. 14, 2010). A  1099C form serves as evidence of  a canceled debt with      18
regard to the discrepancy between the mortgage balance and the foreclosure sale price. Under the Mortgage
Forgiveness Debt Relief Act of 2007, any potential tax liability for a deficiency on a residential property is
usually forgiven on debts up to $2 million in forgiven debt. See, e.g., IRS Publication 908. In contrast, a 1009A
form generally indicates potential debt and tax liability issues.
 Exs. M-P (2010 correspondence related to the foreclosure).      19
 Tr. 44.      20
4
continue living elsewhere.  He then ceased making payments on the townhouse and14
put the property on the market while awaiting final word on his loan modification
request. It was his hope to roll over any arrearage into the modified loan, but his
request was eventually denied.15
Through his efforts, Applicant ultimately secured a ratified contract for a short
sale on the townshouse. He was offered $129,000 for the property, on which he owed
approximately $185,000.  Applicant was initially told a short sale might be permissable.16
His second mortgage holder said it would agree with the short sale if the primary lender
agreed to it. The primary lender (SOR allegation ¶ 1.c), however, would not agree to the
short sale. Applicant contacted his local congressman for assistance to slow down the
foreclosure process in order to complete a short sale, but approval for the sale could
not be obtained despite previous indications that a short sale might be permitted.17
Foreclosure proceedings followed in early 2010, about six months after Applicant was
no longer able to make mortgage payments on the house. The house was then
auctioned. In a December 2010 letter from his primary lender, Applicant was notified
that he would receive an IRS 1099C form for tax year 2010.  Despite his best efforts,18
Applicant was unable to learn more about the auction, the foreclosure, or his current
standing.  He has not received official notification as to how his secondary lender19
would treat the foreclosure, although he noted its prior deferral to his primary lender’s
actions.
At the time of the foreclosure, Applicant had not had any financial issues since
he declared bankruptcy in 1998. That bankruptcy followed a period of financial
instability that coincided with the purchase of Applicant’s first marital home shortly
before his salary as a state police officer was stalled, and his wife had their two sons.20
Since that time, Applicant has budgeted his income and his salary has risen. In 2009,
for example, he was earning approximately $71,500 a year; in 2010, Applicant was
 Ex. A (Pay stubs from Mar. 2009 and Nov. 2010). Annual salary calculations are estimated using      21
Applicant’s current base salary distributions, multiplied by 26 pay periods per year.
 Tr. 70.      22
 Tr. 56.      23
 Tr. 25.      24
 Tr. 74.      25
 Tr. 95-96.      26
 Tr. 95.      27
 Tr. 109. Applicant’s brother noted that Applicant has become more conservative and parsimonious in the      28
past few years. Tr. 109-114.
 Ex. P (Budget). Applicant maintains two credit cards. He showed that he  budgets to pay more than the      29
monthly minimum payment on his active credit card. See also Tr. 78-79.
 Tr. 43.      30
5
earning close to $90,000.  He is currently living within his means and is highly valued21
as an employee at his workplace. 
Before Applicant received verification that he would be issued a 1099C, rather
than a 1099A, Applicant was prepared to address any resultant liability on his
residential property.  He has made regular mortgage payments on the house located in22
a state to the south of his current region of residence.  He made regular child support23
payments through payroll deduction until an agreement was reached under which he
took physical custody and financial responsibility for his older child, while his ex-wife did
the same for the younger child.  He has not pursued financial counseling.  However,24 25
he has learned a lot about the pitfalls of renting properties and mortgages.  With a26
better understanding of these ventures, Applicant is now more cautious. He will not do
anything that will jeopardize his job in the future.  He is also more mature.  Applicant27 28
leads a simple life with no luxuries of note. His current monthly income is about $4,714
and his expenses are approximately $3,101, leaving him a net surplus of about $1,612
a month.  He now maintains a modest 401k account. 29
At issue in the April 2010 SOR are five alleged debts, three of which Applicant
was unaware until his receipt of the SOR. Those debts are noted at ¶¶ 1.a, 1.d, and
1.e. The Government, in noting that those alleged debts only amount to about $800,
emphasized that its major concerns were with regard to the debts reflected in
allegations ¶¶ 1.b - 1.c.  In sum, the five alleged debts at issue are represented in the30
following five SOR allegations:
¶ 1.a – Telecommunications debt, $467. Charged-off account. Status unclear. This
account was opened in 2006 and its status was last reported in December 2009. The
credit report offered as Ex. 4 (Mar. 4, 2010) does not include an account number,
 Tr. 37.      31
 Ex. H (Bank statements, dated Dec. 22, 2009 – Nov. 19, 2010).      32
 Tr. 35-36.      33
 It is also noted that Applicant’s multiple moves may have led to the creation of an outstanding balance      34
that may have gone unnoticed by both Applicant and the creditor. Tr. 38.
 Therefore, it would appear the house was treated as Applicant’s residence, a status that should have      35
remained the same in his secondary lender’s assessment of the situation.
 Tr. 39.      36
6
contact information, or other identifying information about this account, except that it
notes the account was closed at consumer’s request. The Government conceded the
reference code noted in Ex. 4 is an internal identification code and not an account
number.  Applicant provided bank statements showing current payments on an31
account with the same leading national telecommunications provider continuing into
2010, but there is no evidence directly linking that account with the one undefined
account at issue.  Because the account at issue is impossible to distinguish, Applicant32
credibly testified that he has had only one account with this creditor, a combined
account for cellular and landline service, and noted that he is unaware of any
outstanding debt to this entity.  The account is with one of the three leading national33
telecommunications entities. It is noted that this industry commonly either carries over
delinquent balances or denies service when an outstanding balance is at issue.34
¶ 1.b – Second mortgage-related debt, $2,474 past due on account in foreclosure with
a total loan balance of $35,570. Status unclear. This debt concerns the last property
Applicant acquired, which is discussed above. Applicant had no evidence whether he
would receive a 1099C for this property, but showed that in the past, this lender
deferred to the actions of the primary lender. 
¶ 1.c – First mortgage-related debt, $18,498 past due on account in foreclosure with a
total loan balance of $141,000. Addressed. This debt concerns the last property
Applicant acquired, which is discussed above. He was notified that he would receive a
1099C form regarding the post-auction status of his loan.  35
¶ 1.d – Education-related debt, $284. In collection. Status/origin unknown. This account
is not reflected in the credit reports submitted by the Government in its exhibits, but is
referenced only by name in 2009 interrogatories.  There is no indication as to what36
source or credit reporting bureau served as the basis for this allegation. Therefore,
neither account nor contact information is available for the Applicant’s review or in the
record. Applicant denied knowledge of this alleged debt. He last attended a college-
level course in about 2007, at a state college. Applicant’s February 2009 security
clearance application notes no other post-secondary institutions. He testified that he
had no outstanding balances, which he previously demonstrated by offering
 Ex. 2 (Interrogatories, dated Dec. 3, 2009) at 5.      37
 Id. at 8.      38
 Id. at 4-5.      39
 It may be assumed the code represents a creditor, as designated by one of the credit reporting bureaus,      40
but there is no indication as to which credit reporting bureau, if any, was the original source.
 Tr. 39, 41.      41
 Ex. 2, supra, note 37, at 5.      42
7
interviewers a copy of his transcripts.  He also provided a copy of a 2009 registration37
statement showing that he had a zero balance with this institution, with his last payment
shown as having been made in 2007 for his last class from that same year.  He has38
consistently testified, in his interrogatories and at the hearing, that he has
unsuccessfully researched the origin of this alleged account.
¶ 1.e – Medical debt, $284. In collection. Status/origin unknown. This account is not
reflected in the credit reports submitted by the Government in its exhibits. As with the
debt noted at ¶ 1.d, there is no indication as to what source or credit reporting bureau
served as the basis for this allegation. The alleged debt is only referenced in the 2009
interrogatories constituting Ex. 2. In the interrogatories, the alleged debt is only
identified by creditor identification code reference number.  No other information is39
noted. The reference code noted is not linked to a specific credit reporting bureau.40
Applicant has consistently stated that he cannot identify this alleged debt and that he
has unsuccessfully tried to research its origin.  Unable to identify the alleged debt or its41
source, Applicant cannot dispute the alleged debt. He is willing to pay any bona fide
debt owed, but is unable to identify the creditor based on the Government’s evidence.42
Policies
When evaluating an applicant’s suitability for a security clearance, an
administrative judge must consider the AG. In addition to brief introductory explanations
for each guideline, the AG list potentially disqualifying conditions and mitigating
conditions. 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. Under AG ¶ 2(c), this
process is a conscientious scrutiny of a number of variables known as the “whole-
person concept.” The administrative judge must consider all 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
 See also ISCR Case No. 94-1075 at 3-4 (App. Bd. Aug. 10, 1995).      43
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      44
 ISCR Case No. 07-16511 (App. Bd. Dec. 4, 2009) (citing Directive ¶¶ E3.1.32.3 and E3.1.33.3; see ISCR      45
Case No. 09-03773 (A.J. Jan. 29, 2010) discussing appellate standards of review).
 Id.      46
 Id.      47
8
decision, I have drawn only those conclusions that are reasonable, logical, and based
on the evidence contained in the record.
The Government must present evidence to establish controverted facts alleged
in the SOR. An 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 burden of proof is something less than a preponderance of43
evidence. The ultimate burden of persuasion is on the applicant.  The DOHA Appeal44
Board may reverse the administrative judge’s “decision to grant, deny, or revoke a
security clearance if it is arbitrary, capricious, or contrary to law.”45
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 about 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). “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 applicant should be allowed access46
to sensitive information must be resolved in favor of protecting such sensitive
information.47
Based upon my consideration of the evidence, Guideline F (Financial
Considerations) is  the most pertinent to this case. Conditions pertaining to this AG that
could raise a security concern and may be disqualifying, as well as those which would
mitigate such concerns, are set forth and discussed below.
 AG ¶ 18.      48
 Id.      49
9
Analysis
Guideline F - Financial Considerations 
Under Guideline F, “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.”  It48
also states that “an individual who is financially overextended is at risk of having to
engage in illegal acts to generate funds.”  Applicant bought a residential property49
through a primary and a secondary lender. That property ultimately was auctioned in
foreclosure. In addition, three minor debts were alleged as delinquent, which Applicant
admits could be his. Such facts are sufficient to raise Financial Considerations
Disqualifying Condition (FC DC) AG ¶ 19(a) (inability or unwillingness to satisfy debts)
and FC DC AG ¶ 19(c) (a history of not meeting financial obligations). With such
conditions raised, it is left to Applicant to overcome the case against him and mitigate
security concerns. 
The debts at issue are multiple in number. Two of the debts are mortgage-
related, arising from the same property purchase. The remaining three debts are
nominal. Of those nominal debts, one appears to have been addressed or erroneous,
while the other two are insufficiently identified for Applicant to further investigate. The
evidence indicates that Applicant applied some degree of diligence in avoiding
foreclosure of the townhouse by taking roommates, seeking new tenants, applying for
both a loan modification and refinancing, and securing a short-sale buyer to avoid
foreclosure before his primary lender decided not to accept his willing buyer. He and his
witness credibly testified that he has learned much about real estate and rental
management over the past few years, and that Applicant is wary of repeating similar
scenarios in the future. In light of his diligence and the lessons he has learned, it is
unlikely he will again venture into real estate without considerably more advice and
planning. Given these circumstances, 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) applies. 
Many of the conditions at play with regard to Applicant’s house issues were
beyond his control. His seemingly attractive townhouse, in which he hoped to live with
his young son, proved to be in an increasingly dangerous neighborhood. Consequently,
he rented an apartment in order to provide a safe environment for his child. The real
estate market then turned sour. He was unable to find suitable renters. He
unsuccessfully applied for a home loan modification, then unsuccessfully sought
refinancing. When he thought he had approval to negotiate a short sale, he secured a
bona fide offer and the tentative approval of his secondary lender, but his short sale
was ultimately denied by his primary lender. The property was presumably sold for less
 Tr. 120.      50
10
than the balance on Applicant’s loan.  Such facts indicate factors out of Applicant’s50
control. However, it was Applicant who chose to stop making payments on the property,
an act which led to foreclosure. While he may have done so due to a depletion of
available financial resources, this act was not outside of his control. Consequently, 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) only applies in part.
Applicant has not received financial counseling, obviating application of FC MC
AG ¶ 20(c) (the person has received or is receiving counseling for the problem and
there are clear indications that the problem is being resolved or is under control).
When Applicant, for safety reasons, was forced to rent an alternative place to
live when he discovered his new townhouse was in a dangerous area, he did so after
finding roommates to help meet his mortgage obligations. When he moved, he
unsuccessfully tried to find a reliable tenant, secure a home loan modification, and seek
approval for refinancing at more favorable terms. His successful attempt to find a short
sale buyer was quashed when his primary lender would not approve the sale. After the
house was auctioned in foreclosure in early 2010, he waited a year before receiving
word that he would be issued a 1099C form from his primary lender, thus cancelling his
obligation for any discrepancy between his loan and the sale price. In the interim, he
stood prepared to address any resultant obligation. As for the three minor debts at
issue, Applicant provided credible and consistent testimony that he has tried to
research those debts, but to no avail. FC MC AG ¶ 20(d), (the individual initiated a
good-faith effort to repay overdue creditors or otherwise resolve debts) applies.
The burden for mitigation in these proceedings is placed squarely on Applicant.
This case is not one of an individual investing in risky ventures or indulging in luxuries.
In order to maintain relations with his children, Applicant relocated and bought a home.
He soon discovered the area was unsafe and had to rent another place to live and care
for his eldest child. From there, Applicant unsuccessfully attempted many logical
strategies to meet his mortgage obligations before the property went into foreclosure.
At the hearing, the Government expressed its concern that, at the time, it was
unclear what, if any, deficiency balance might be owed for the mortgaged townhouse.
After the hearing, Applicant provided evidence that a 1099C would be issued with
regard to his primary lender. As for the secondary lender, it may be assumed that, at
best, it will follow the primary lender in issuing a 1099C or, at worst, encumber
Applicant with a singular debt of manageable worth. Regardless, Applicant provided
sufficient evidence that he devised and executed a reasonable strategy to meet his
mortgage obligations through roommates, tenants, refinancing, and sale until he was
simply unable to make payments on the property. After the house went into foreclosure,
he sought the aid of his congressman to delay foreclosure, but that effort could not
forestall action by his lender. After the home was auctioned, he stood prepared to
11
address any resultant obligation. The evidence indicates the vast majority of that debt
was cancelled without tax repercussions. In the unlikely event there may be some
liability attached to his second mortgage, that sum would be comparatively minor, and
Applicant credibly expressed his commitment to addressing his debt. Given his current
monthly remainder after expenses of over $1,600 a month, he has the ability to meet
such a balance.
Whole-Person Concept
Under the whole-person concept, an administrative judge must evaluate an
applicant’s eligibility for a security clearance by considering the totality of an applicant’s
conduct and all the circumstances. An administrative judge should consider the nine
adjudicative process factors listed at AG ¶ 2 (a). Under AG ¶ 2(c), the ultimate
determination of whether to grant a security clearance must be an overall
commonsense judgment based on careful consideration of the guidelines and the
whole-person concept. In addition, what constitutes reasonable behavior in such cases,
as contemplated by FC MC ¶ 20(b), depends on the specific facts in a given case. 
I considered the potentially disqualifying and mitigating conditions in light of all
the facts and circumstances surrounding this case, as well as the “whole-person”
factors. Applicant is a highly credible and candid 39-year-old senior network engineer
who is a highly valued employee. He volitionally pursued some post-secondary
education after completing high school. He is a devoted father who has twice relocated
in order to provide his children with paternal love and security. He made his elder child’s
safety his paramount concern when he left his home and rented an apartment in a safer
area. He demonstrated considerable diligence in personally taking more responsibility
over his ownership and the management of his former home after it was “trashed” by
poor tenants and mismanaged by negligent real estate agents. Since 2009, he has tried
to fathom the origin of two of the three smaller debts at issue, but both the alleged
creditor and the credit bureau reporting source remain undefined. As for the third
smaller debt, the fact he still maintains service with the creditor-telecommunications
provider strongly suggests the matter was resolved or the credit reporting bureau entry
is in error. 
When Applicant vacated his townhouse in order to find a safer haven for himself
and his child, he had to rent an apartment. He later moved in with a girlfriend, with
whom he shared expenses. To offset this unforseen expense, he sought out
roommates. He actively worked to find renters. He then endeavored to seek a home
loan modification. Next, he sought refinancing, hoping to apply any arrearages to his
refinanced loan. Refinancing was denied, and the real estate market continued in a
downward trend. When he thought he had approval to execute a short sell, he found a
willing buyer. That attempt, however, was ultimately blocked by his primary lender.
Refuge to his local congressman to forestall foreclosure was insufficient. When the
property was auctioned, he stood prepared to address any liability. He later received
evidence that his primary lender on the residence would provide him with 1099C relief.
Given this fact, it is highly likely that his secondary loan will similarly be subject to
cancellation. If it is not, however, Applicant has both the intention, commitment, and
financial resources to address any resultant balance owed on the smaller loan. 
12
Applicant demonstrated a rising sense of responsibility and understanding of real
estate finances commensurate with personal maturation and increased financial
resources. He lives a simple life and eschews unnecessary expenditures. He limits his
credit card use. He now lives within his means and has a notable monthly net
remainder to address any unexpected debts. While his foreclosure raised genuine
security concerns, the unique facts leading to his move from that home and the
assumption of unforeseen expenses in finding a new place to live do not demonstrate
frivolity or a capricious nature, but a genuine concern for safety. He devised and
executed a methodical plan to keep the home and meet his financial obligations until
both his resources and options were depleted. I conclude that Applicant exhibited
reasonable behavior under the circumstances, and I have no concerns that he will
again fall prey to financial problems. Given all these considerations, there is sufficient
evidence to mitigate Guideline F security concerns. Clearance is granted.      
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
Subparagraphs 1.a-1.e: For Applicant
Conclusion
In light of all of the circumstances presented by the record in this case, it is
clearly consistent with national interest to grant Applicant a security clearance.
Clearance granted.
ARTHUR E. MARSHALL, JR.
Administrative Judge