DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of:                                            )
                                                                     )
----------------------------------  )       ISCR Case No. 10-03102
                                                            )
   )
Applicant for Security Clearance  )
Appearances
For Government: Braden Murphy, Esquire, Department Counsel
For Applicant: Pro se
______________
 Decision
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W ESLEY, Roger C., Administrative Judge:
Based upon a review of the pleadings, exhibits, and testimony, Applicant failed to
mitigate security concerns over personal conduct issues associated with his misuse of a
corporate credit card and the state of his finances.  Clearance is denied. 
Statement of the Case
On March 7, 2011, the Defense Office of Hearings and Appeals (DOHA) issued a
Statement of Reasons (SOR) to Applicant detailing reasons why DOHA could not make
the preliminary affirmative determination of eligibility for granting him a security
clearance. DOHA recommended referral to an administrative judge to determine whether
a security  clearance should be granted, continued, denied, or revoked. 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 Adjudicative Guidelines for Determining Eligibility for
Access to Classified Information (AGs) that were implemented by the Department of
Defense on September 1, 2006.
. 
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Applicant responded to the SOR on April 4, 2011, and requested a hearing before
an administrative judge. The case was assigned to me on May 20, 2011, and was
noticed on June 2, 2011 for a hearing on June 22 2011. A hearing was held on the
scheduled date. At the hearing, the Government's case consisted of ten exhibits (GEs 1-
10). Applicant relied on one witness (himself) and 11 exhibits (AEs  A-J). The transcript
(Tr.) was received on June 30, 2011. 
Procedural Issues
Before the commencement of the hearing, Department Counsel moved to amend
the SOR to delete subparagraph 1.e from the SOR and re-allege it under a new financial
considerations guideline as subparagraph 2.a.  There being no objection from Applicant,
and for good cause shown, Department Counsel’s motion was granted. 
Prior to the close of the hearing, Applicant requested the record be kept open to
afford him the opportunity to supplement the record with documented proof of his payoff
of his Government credit card balance and a new payment plan with the creditor listed in
subparagraph 2.a. For good cause shown, Applicant was granted seven days to
supplement the record. The Government was afforded six days to respond. Within the
time permitted, Applicant supplemented the record with an explanatory letter and
documentation of his payoff to creditor 1.a and a payment plan arrangement with the
creditor listed in subparagraph 2.a. Applicant’s submissions were admitted as AEs K
through M.    
Summary of Pleadings
Under Guideline E, Applicant allegedly (a) failed to pay his corporate credit card
bill as agreed, even though he was reimbursed by his company for his travel expenses;
(b) provided false information to his employer, stating that he was paying his corporate
credit card bill, even though he knew this was not true; (c) in December 2009, his
corporate credit card was canceled, the $12,564 balance was paid by his employer, and
$500 per pay period was deducted from his paycheck to satisfy this debt; (d) in
December 2009, his employer issued a final notice for dishonesty, negligence, and
improper use of his corporate credit card; and (e) he is indebted to a car lender on a
charged-off account in the approximate amount of $13,867. 
In his response to the SOR, Applicant admitted most of the allegations with some
explanations.  He denied providing false information about his payments to his employer.
He claimed he had discussions with the creditor that led to his minimum payment
arrangements with the creditor.
      Findings of Fact
Applicant is a 54-year-old engineering technician for a defense contractor, who
seeks to retain his security clearance. (GE 1) The allegations covered in the SOR and
admitted by Applicant are adopted as relevant and material findings.  Additional findings
follow.
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Background
Applicant married his first wife (W1) in February 1979 and divorced her in July
1980. (GE 1) He has three children from this marriage, ages 31, 28, and 26. (GE 1; Tr.
67) In June 1985, Applicant married his second wife (W2); he divorced her in April 1993.
(GE 1) He married his third wife (W3) in July 1993 and divorced her in January 2007.
(GE 1; Tr. 66, 70). 
Applicant has one semester of college credits but no degree or diploma. (GE 1;
Tr. ) He enlisted in the Navy August 1979 and served 15 years of active duty. (GE 1; AE
B) While in the Navy, he held a top secret clearance. (Tr. 63) Applicant received an
honorable discharge with the rank of chief petty officer in January 1993. (AE B; Tr. 62)
For the first three years following his discharge (1993-1996), he worked for another
contractor. (Tr. 63-64) He has  worked for his current employer since April 1996 and has
held a security clearance for the duration of his employment. (GEs 1 and 8; AE B; Tr. 63)
Finances 
Applicant first encountered financial difficulties in April 2009. (GE 2; Tr. 67) He
attributed his difficulties to his trying to help his children and former spouse with their
own financial needs. Besides helping his son with car repairs and his oldest daughter
with a car purchase, he advanced $10,000 to W1 (while they were separated but not yet
divorced) to start a business, rent a new home, and purchase a new BMW vehicle. (GE
4; Tr. 50-51, 67-70, 70-73, 93-94) These financial assistance efforts contributed to his
ensuing misuse of his corporate credit card, and subsequently the repossession of the
BMV vehicle he and his ex-wife purchased together. (GE 2) 
Between April 2009 and August 2009, Applicant used his corporate credit card for
both travel-related purchases and personal expenditures unrelated to his travel
assignments. (GE 4; Tr. 68-69)  He counted on the reimbursements from his travel card
to cover the travel and personal expenditures he used to help his wife and children. (GE
2; Tr. 74, 76-77, 80, 93-94)  With the reimbursement travel checks from his employer, he
often used the funds to cover his personal obligations instead of using them to repay his
corporate credit card account. (GE 4; Tr. 76-77, 80) Payment records do reflect Applicant
payments of $3,500 in May 2009 and $2,000 in July 2009. (GE 4)
Applicant signed a corporate credit card agreement with his company’s credit card
issuer in October 2003. (GE 5) In this agreement, Applicant agreed to use his corporate
credit card exclusively for overhead-related travel expenses and direct charge, contract-
related travel expenses. He was expressly forbidden from using the corporate card for
personal or non-travel charges. (GE 5) In return for his receipt of a corporate travel card,
he agreed to pay the issuer “promptly for all business charges incurred upon receipt of
the monthly billing statement.” (GE 5) He agreed to indemnify his company for any loss,
claim, or expense arising from his failure to reimburse the issuer when charges came
due. And he acknowledged in his agreement that any misuse of his corporate credit
card, or violation of the terms and conditions of use, would result in disciplinary action.
(GE 5)
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By October 2009, Applicant’s accrued expenditures on his corporate credit card
for travel and personal expenses approximated $13,845. (GE 4). He was cited by the
corporate creditor with being over 150 days delinquent on his corporate credit card bill.
(GEs 7 and 9) E-mail exchanges and a completed incident report (GEs 6 and 9) cite
misleading Applicant accounts to his supervisor about paying his corporate credit card
account on-line. Applicant disputes these claims and assures he kept his supervisor
informed of his delinquent corporate credit card account and made two $1,000 payments
on the account in October 2009. (Tr. 55-58, 79-80, 117). Applicant’s assurances are
documented in his corporate credit card payment history; supported in his current
supervisor’s endorsement (AEs A and E); and are not disputed in the counseling form he
accepted and signed. (GE 8) Applicant’s versions of his exchanges with his supervisor
about the status of his corporate credit card account are plausible ones and are
accepted. 
The corporate credit card issuer later credited Applicant with a $5,000 on-line
payment in June 2009 and  two $1,000 on-line payments in October 2009. (GE 4; AE E)
His November 2009 corporate credit card statement reflected an ending balance of
$12,564 and no additional payments on the account.  (GE 4; Tr. 87-88) Shortly
thereafter, the credit card issuer cancelled Applicant’s corporate credit card  and notified
his employer. (GE 6)
Upon being advised by both Applicant and the credit card issuer in November
2009 that Applicant was 150 days in arrears on his corporate credit card account in the
amount of $12,564, Applicant’s supervisor reviewed the history of the account and
advised Applicant that he had been reimbursed on his corporate credit card
expenditures and needed to work out a payment arrangement to discharge the
remaining balance. (GEs 8 and 9)  
Based on the documented internal investigation of Applicant’s reported corporate
credit card misuse, Applicant was issued a final written warning in December 2009
covering his corporate credit card use. (GE 8) In the summary furnished Applicant, his
supervisor cited Applicant’s dishonesty in the use of his corporate credit card and his
failure to pay the billed amount on the card after he has been reimbursed by his
employer. (GE 8). After counseling Applicant in December 2009, Applicant’s supervisor
found Applicant misused his corporate credit card. (GEs 8 and 9)                                      
                                                                                                                          
As a part of the disciplinary action imposed on Applicant by his supervisor for
misusing his corporate card and accruing a large balance of unpaid charges, Applicant
agreed to repay his employer who had paid off the accrued corporate credit card  debt of
$12,564 and looked to Applicant for its reimbursement. (AE E; Tr. 81-84) In turn,
Applicant agreed to a repayment schedule as follows: $500 per pay period through a
payroll deduction until the accrued amounts are paid in full and repayment of the entire
remaining balance from his final paycheck in the event his employment were to terminate
before the agreed amounts had been satisfied. (GEs 7 and 8) Applicant was also
advised as a part of his disciplinary action that his corporate credit card had been
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canceled and that any failure to pay on his credit card balance may result in further
disciplinary action, up to and including termination. (GE 8) 
Applicant’s corporate credit card payment history reflects a beginning year
balance in January 2010 of $12,587 and bi-weekly payments of $500 through 2010.  (AE
L) He is credited with making a final payment of $1,064 in December 2010 to satisfy his
delinquent corporate credit card account in full. (AE L)  
Since relinquishing his corporate credit card, Applicant has not received a
replacement.  When he travels on business trips, his company currently furnishes him an
advance travel payment comprising 80 per cent of his per diem requirements. (Tr. 89-90)
As a consequence of his misusing his corporate credit card, his company demoted him
to the position of team leader and placed him under an hourly pay schedule. (Tr. 92)   He
has since been restored to near-normal salary levels. (Tr. 92)   
Besides accumulating delinquent personal and travel-related charges on his
corporate credit card, Applicant accrued a deficiency on a BMW purchase agreement he
co-signed on behalf of W3 in April 2009 for the purchase of a new BMW vehicle at a cost
of over $40,000. (AE I) Applicant and his third wife co-registered the vehicle with his
state’s department of motor vehicles in their joint names. (GE 2 and AEs G and H; Tr.
50-51, 93-94, 102). Assuming she was making the required monthly payments on the
vehicle, he made no effort to personally track her payments. (Tr. 51, 93)
In September 2009, Applicant received a call from the lender informing him that it
had received no payments in four months and threatening him with repossession. (GE 2)
After bringing the account current (AE J), he received a call from the same lender two
months later that they had not received any additional payments. Unable to cover W3's
payments any longer with his personal resources, Applicant told the lender to repossess
the vehicle from his ex-spouse. (GE 2 and AE J)
After repossessing the vehicle, the lender looked to Applicant for the payment of
the remaining balance following public sale of the vehicle. (GE 2 and AE I; Tr. 96-97)
When Applicant did not address the deficiency balance, the lender charged off the
remaining $13,867 balance on the purchase contract. (GE 10; Tr. 97-98) 
In August 2010, Applicant filed suit against W3 for reimbursement of the
expenditures he was obligated to make when she failed to make her BMW payments as
agreed. (AE D) W3 countered with the filing of a petition for bankruptcy protection. (Tr.
99) The status of W3's bankruptcy and Applicant’s pending suit are unclear. (Tr. 99-100,
118) 
Following the hearing, Applicant contacted the collection agency for the lender
about his BMW account. (AE M) He set up a 36-month payment plan with the collection
agent for creditor 2.a covering the outstanding deficiency balance ($13,867). Under his
payment plan with creditor 2.a, Applicant will make payments of $385 a month, with
payments due to commence in July 2011. (AE M; Tr. 116) Applicant has not provided
any evidence of monthly payments under his payment plan, and it is unclear at this point
whether he has made any payments to creditor 2.a or its collection agent.
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Applicant is current with his remaining debts. (AE C; Tr. 100-101) He reports
gross annual income of $72,000. (Tr. 106)  He owns a home and has a monthly
remainder of $450 after accounting for his mortgage, alimony ($500 a month), and other
expenses. (Tr. 108, 116) He has approximately $20,000 in his 401(k) retirement account.
(Tr. 110)
Endorsements
During his active duty military service, Applicant received numerous medals and
citations recognizing his military contributions to the Navy. (AE B) His medals and
citations include the National Defense Service Medal; Sea Service Deployment Ribbon
with Three Stars; and the Navy Achievement Medal. (AE B)  He is well regarded by his
project manager and members of his employer group. (AE A) His project manager, who
served as his employer’s facility security officer, credits him with leadership skills,
honesty, and high performance in his work assignments. (AE A)
Policies
The AGs list guidelines to be used by administrative judges in the decision-
making process covering DOHA cases. These guidelines take into account factors that
could create a potential conflict of interest for the individual applicant, as well as
considerations that could affect the individual’s reliability, trustworthiness, and ability to
protect classified information. 
These guidelines include "[c]onditions that could raise a security concern and may
be disqualifying” (disqualifying conditions), if any, and many of the "[c]onditions that
could mitigate security concerns.” They must be considered before deciding whether or
not a security clearance should be granted, continued, or denied. The guidelines do not
require administrative judges to place exclusive reliance on the enumerated disqualifying
and mitigating conditions in the guidelines in arriving at a decision. Each of the
guidelines is to be evaluated in the context of the whole person in accordance with AG ¶
2(c) 
In addition to the relevant AGs, administrative judges must take into account the
pertinent considerations for assessing extenuation and mitigation set forth in AG ¶ 2(a)
of the revised AGs, which are intended to assist the judges in reaching a fair and
impartial commonsense decision based upon a careful consideration of the pertinent
guidelines within the context of the whole person. The adjudicative process is designed
to examine a sufficient period of an applicant’s life to enable predictive judgments to be
made about whether the applicant is an acceptable security risk. 
When evaluating an applicant’s conduct, the relevant guidelines are to be
considered together with the following AG ¶ 2(a) factors: (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 chances; (7) the motivation for the conduct; (8) the potential for
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pressure, coercion, exploitation, or duress; and (9) the likelihood of continuation or
recurrence.
Viewing the issues raised and evidence as a whole, the following adjudication
policy concerns are pertinent herein:
Personal Conduct
The Concern: Conduct involving questionable judgment, untrustworthiness,
unreliability, lack of candor, dishonesty, or unwillingness to comply with rules and
regulations can raise questions about an individual’s reliability, trustworthiness and ability
to protect classified information.  Of special interest is any failure to provide truthful and
candid answers during the security clearance process or any other failure to cooperate
with the security clearance process.  AG, ¶ 15.
Financial Considerations
The Concern: 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. Compulsive gambling is a concern as it may lead to financial crimes
including espionage. Affluence that cannot be explained by known sources
of income is also a security concern. It may indicate proceeds from
financially profitable criminal acts.  AG ¶ 18.
Burden of Proof
Under the Directive, a decision to grant or continue an applicant's request for
security clearance may be made only upon a threshold finding that to do so is clearly
consistent with the national interest. Because the Directive requires administrative
judges to make a commonsense appraisal of the evidence accumulated in the record,
the ultimate determination of an applicant's eligibility for a security clearance depends, in
large part, on the relevance and materiality of that evidence. As with all adversarial
proceedings, the judge may draw only those inferences which have a reasonable and
logical basis from the evidence of record. 
The Government's initial burden is twofold: (1) It must prove by substantial
evidence any controverted facts alleged in the SOR; and (2) it must demonstrate that the
facts proven have a material bearing to the applicant's eligibility to obtain or maintain a
security clearance.  The required showing of material bearing, however, does not require
the Government to affirmatively demonstrate that the applicant has actually mishandled
or abused classified information before it can deny or revoke a security clearance.
Rather, consideration must take account of cognizable risks that an applicant may
deliberately or inadvertently fail to safeguard classified information.
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Once the Government meets its initial burden of proof of establishing admitted or
controverted facts, the burden of proof shifts to the applicant for the purpose of
establishing his or his security worthiness through evidence of refutation, extenuation or
mitigation of the Government's case. Because Executive Order 10865 requires that all
security clearances be clearly consistent with the national interest, “security-clearance
determinations should err, if they must, on the side of denials.” See Department of the
Navy v. Egan, 484 U.S. 518, 531 (1988).
Analysis  
Applicant is a respected engineering technician of a defense contractor who
accumulated delinquent debts associated with his misuse of a corporate credit card and
assumed legal responsibility for a leased vehicle co-signed by Applicant and his ex-wife.
Security concerns arise under both the personal conduct and financial considerations
guidelines.  
Personal conduct issues associated with misuse of corporate credit card
Judgment and trust lapses associated with Applicant’s misuse of his corporate
credit card, the credit card cancellation and other disciplinary actions taken against him
by his employer in December 2009 were both justified and appropriate. Sanctions
included relinquishment of his company credit card, demotion, and continued oversight
by his supervisor and administrative staff. To be sure, Applicant has never been cited
before for any indiscretion or judgment lapse and is recognized and respected for his
many contributions to his company’s missions and for his years of meritorious military
service.
Still, Applicant understood both the letter of the credit card agreement he signed
in 2003 and the card’s use restrictions. Applicant’s repeated misuse of his corporate
credit card over a six-month period poses potentially serious personal conduct concerns.
These underlying security concerns are difficult to reconcile with the trust and reliability
requirements for holding a security clearance.  
Looking at the developed facts and circumstances in this case, two of the
disqualifying conditions under the personal conduct guideline are applicable to
Appellant’s situation.  DC ¶ 16(d)(3), “a pattern of dishonesty or rules violations,” and DC
¶ 16(d)(4), “evidence of significant misuse of Government or other employer’s time or
resources,” have application to the facts of Appellant’s case.  
Holding a security clearance involves a fiduciary relationship between the
Government and the clearance holder. Quite apart from any agreement the clearance
holder may have signed with the Government, the nature of the clearance holder’s duties
and access to classified information necessarily impose important duties of trust and
candor on the clearance holder that are considerably higher than those typically imposed
on Government employees and contractors involved in other lines of government
business. See Snepp v. United States, 444 U.S. 507, 511 n.6 (1980).
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While Applicant’s strained finances played a major role in his misusing his
corporate credit card, they were not enough to credit him with extenuating
circumstances.  Nor is his corporate credit card misuse over an extended period of time
so minor or unique as to render a recurrence unlikely. See ISCR Case No. 03-24632 at 3
(Appeal Bd. May 19, 2008). As a result, Applicant may not rely on the mitigating benefits
of MC ¶ 17(c), “the offense is so minor, or the behavior is so infrequent, or it happened
under such unique circumstances that it is unlikely to recur and does not cast doubt on
the individual’s reliability, trustworthiness, or good judgment.”
To Applicant’s credit, he acknowledged his mistakes in using his corporate credit
card to accrue large unpaid balances, some unrelated to travel-related activities; he was
truthful with his supervisor about his past corporate credit card payments when asked,
and he accepted counseling and the disciplinary conditions imposed on him by his
supervisor. MC ¶ 17(d), “the individual has acknowledged the behavior and obtained
counseling to change the behavior or taken other positive steps to alleviate the stressors,
circumstances, or factors that caused untrustworthy, unreliable, or other inappropriate
behavior, and such behavior is unlikely to recur,” has some applicability to Applicant’s
circumstances.
Whether Applicant has learned enough from his past mistakes of his ignoring use
and payment conditions on his corporate credit card to avert any recurrences is not fully
certain. Although he has since repaid the account balance on the credit card in
accordance with the terms and conditions set by his disciplinary agreement, it is still
unclear whether enough time has passed to ensure he will not abuse imposed credit
card restrictions in the future when placed in stressful circumstances. He remains subject
to restricted travel conditions that limit him to travel advances in lieu of a corporate credit
card, and his employer has not fully restored him to his original position before
disciplinary conditions were imposed in 2009.  
Evaluating Applicant from a whole-person perspective is aided by his documented
proof of paying off his corporate credit card balance in accordance with the schedule he
agreed to with his supervisor in 2009.  His 15 years of active military service are worthy
of considerable credit. Lessons learned from his military service could be expected to
impress upon him the high standards of trust and reliability expected of him by his
military and civilian employers alike. 
When Applicant elected to misuse his corporate credit card on multiple occasions
throughout 2009, he consciously compromised the high standards of trust and reliability
imbued in him over the course of his 15 years of military service. Considered under
these circumstances, his accumulation of large delinquencies and unrelated travel
expenditures on his corporate credit card (albeit since repaid), while encouraging, are
not enough to absolve him of any lingering doubts about his ability to avert mishandling
of his employer’s credit cards in the foreseeable future. 
Taking into account all of the facts and circumstances surrounding Applicant’s use
of his corporate credit card to defray personal and travel-related expenses and the
documented concrete steps he has taken to date to successfully repay the credit card
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balance, it is still too soon to credit Applicant with mitigating security concerns related to
his misuse of his corporate credit card while employed by his current employer.
Unfavorable conclusions warrant with respect to subparagraphs 1.a, 1.c, and 1.d.
Applicant is credited with giving honest answers to his employer about his corporate
credit card payments, and favorable conclusions warrant with respect to subparagraph
1.b.
Financial issues related to repossession deficiency
Besides accumulating large debt balances on a corporate credit card issued to
him by his corporate employer, Applicant accrued a large deficiency debt on a purchased
vehicle he co-signed with W3. His co-signing a note to facilitate his wife’s purchase of
the BMW vehicle was one of several commitments he made to W3 in 2009 as they were
contemplating separation. 
By all accounts, Applicant obligated to assist W3 at a time when his financial
resources were already beginning to diminish.  Without more historical explanations for
this major debt delinquency, it is difficult to find either extenuating circumstances or
concrete repayment steps sufficient to mitigate security risks associated with his
delinquent debt accrual. 
Once he became aware of W3’s defaults in her payment obligations on the
vehicle Applicant co-signed for, Applicant consented to repossession of the vehicle and
initiated suit against W3 to recoup his losses. With his reimbursement prospects very
much in doubt, he has since entered into a repayment agreement with the lending firm
which had written off the debt. Based on his repayment agreement with this lender,
Applicant may take some advantage of MC ¶ 20(d), “the individual initiated a good-faith
effort to repay overdue creditors or otherwise resolve debts.” 
When addressing repayment efforts generally, the Appeal Board has not required
an applicant to establish “that he has paid off each and every debt listed in the SOR.”
See ISCR Case no. 07-06482 at 2-3 (App. Bd. May 21, 2008)(internal citations omitted).
All that the Board has required is that the “applicant demonstrate he has a plan to
resolve his financial problems and has taken significant actions to implement that plan.”
See id. In Applicant’s case, he has demonstrated some tangible steps to satisfy his
creditor 2.a debt delinquency.  But he provided no proof of any earnest payments made
in accordance with the agreement he reached with creditor 2.a. Quite conceivably, he
will be able to make the regular monthly payments called for in his agreement with the
collection agency for creditor 2.a, but it is by no means certain, given the modest
remainder he has to work with every month.  Without some payment track record with
this creditor and its collection agent, he is not able to fully satisfy any of the pertinent
mitigating conditions.   
Based on a whole-person assessment, Applicant fails to surmount the judgment
questions raised by his accumulation of delinquent debts over an extended period of
time while he was for the most part fully employed. His military awards and
commendations, while impressive, are not enough to overcome judgment risks
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associated with his unresolved finances. On balance, Applicant has not shown sufficient
tangible effort in addressing his debts to mitigate security concerns over his substantial
debt accruals and demonstrate renewed control over his finances. 
Taking into account all of the facts and circumstances surrounding Applicant’s
past debt accumulations, his current $13,867 deficiency balance he has with his car
lender, his military credits, and his meritorious endorsement, it is still too soon to make
safe predictive judgments about Applicant’s ability to safely manage his accounts,
commensurate with established requirements for holding a security clearance.
Unfavorable conclusions warrant with respect to the allegations covered by
subparagraph 2.a.     
Formal Findings 
In reviewing the allegations of the SOR in the context of the findings of fact,
conclusions, and the factors and conditions listed above, I make the following separate
formal findings with respect to Applicant's eligibility for a security clearance.
GUIDELINE E (PERSONAL CONDUCT): AGAINST APPLICANT
Subparagraph 1.a: Against Applicant
Subparagraph 1.b: For Applicant
Subparagraph 1.c: Against Applicant
Subparagraph 1.d: Against Applicant
GUIDELINE F (FINANCIAL CONSIDERATIONS):       AGAINST APPLICANT
Subparagraph 2.a:           Against Applicant
Conclusions
In light of all the circumstances presented by the record in this case, it is not
clearly consistent with the national interest to grant or continue Applicant's security
clearance.   Clearance is denied.
                                  
Roger C. Wesley
Administrative Judge
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