1
                                                             
                           
                        DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
---------------------- )       ISCR Case No. 10-00727
)
)
Applicant for Security Clearance )
Appearances
For Government: William O’Neil, Esquire, Department Counsel
For Applicant: Pro se
                                                                            
______________
Decision
______________
MARSHALL, Jr., Arthur E., Administrative Judge:
On September 10, 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). 
In an undated response, Applicant admitted the 38 allegations raised (¶¶ 1.a-
1.ll), offered two memoranda and 38 attachments, and requested a hearing before a
DOHA administrative judge. DOHA assigned the case to me on November 19, 2010.
The parties proposed a hearing date of January 6, 2011. A notice setting that date for
the hearing was issued on December 16, 2010. I convened the hearing as scheduled. 
Applicant gave testimony and introduced 14 exhibits, which were accepted into
the record without objection as exhibits (Exs.) A-N. She was given through February 4,
2011, to submit any additional documents. The Government introduced 10 documents,
which were accepted into the record without objection as Exs. 1-10. The transcript (Tr.)
 There is no indication that this required extensive time off work or entailed extraordinary out of pocket      1
expenses.
 Tr. 28.      2
2
of the proceeding was received on January 14, 2011. On February 14, 2011,
Department Counsel forwarded eight files received from Applicant. Lacking any
objection to their submission, they were accepted as Exs. O-V. On February 4, 2011, a
comprehensive binder of Applicant’s updated materials was received without objection
and accepted into the record as Ex. W. The record was then closed. Based on a review
of the testimony, submissions, and exhibits, I find Applicant failed to meet her burden of
mitigating security concerns related to financial considerations. Clearance is denied.
Findings of Fact
Applicant is a 38-year-old project support management coordinator who has
worked for the same employer for nearly two years. She earned a bachelor’s degree in
criminal justice and is currently working on a master’s degree in the same field.
Applicant is single and has no children. 
In about October 2002, Applicant underwent necessary surgery, which was
followed by months of recuperation. As she recovered, her company laid off a number
of workers, including her. During this period of unemployment, she acquired many of
the debts that remain at issue. She returned to work in early 2003, but subsequent
periods of employment intermittently followed and her pay was low. In November 2004,
she found a state job, at which she continued to work until about January 2007.  
Over the past decade, Applicant has lived in at least three different states and in
multiple apartment buildings. In late 2006, she accepted a new position. Soon
thereafter, she relocated to take what seemed to be a stable job. She rented an
apartment that she soon discovered was rat infested and which lacked a working air
conditioner, a situation that exacerbated her asthma. Consequently, she was often sick.
Her landlord would not fix the problem or release her from her lease. In about June
2007, she moved closer to her job. Things were starting to improve until she required
an emergency room visit for a kidney stone.  Shortly thereafter, a polyp was discovered1
on one of her vocal cords, necessitating surgery in 2008. Recuperation led to the
depletion of her accrued leave, resulting in her taking unpaid leave on days she was too
ill to work. This situation made it difficult to pay for the extensive medications she was
taking. In October 2008, she broke her ankle and took two weeks off from work. 
In January 2009, Applicant’s cast was removed from her ankle. In May 2009, she
was let go from her job as a contractor and then experienced about three or four
months of unemployment. More erratic employment followed until she started her
current job in late 2009. Around the same time, she was informed that her 2002 surgery
had to be repeated, but she postponed this surgery due to her current work and
financial responsibilities.    2
 Tr. 29.      3
  Note: In Tr. 29-35, Applicant references these events as having occurred in the summer of 2010.  Later      4
in her testimony, when asked to verify the year as 2009, she confirmed the dates as being in 2009. See Tr.
144-145.
 Tr. 145.      5
 Tr. 145.      6
 In summary, of the 38 debts at issue, Applicant showed recent payments amounting to only $165 on six      7
admitted debts amounting to approximately $9,079. Due to recent dispute efforts by her credit repair service,
however, nine accounts have been successfully disputed (1,i, 1.j, 1.l, 1.m, 1,q, 1.r, 1.t, 1.cc, and 1,ee) and
nine are pending dispute resolution (1.g, 1.h, 1.o, 1.u, 1.v, 1.x, 1.y, 1.ff, 1.gg, and 1.hh). In addition, five
complaints have been filed with the Better Business Bureau regarding six accounts (1.b, 1.c, 1.e, 1.f, 1.n, and
1.o). The status of ten alleged accounts, amounting to approximately $5,350, remains unresolved and largely
unaddressed (1.p, 1.s, 1.z, 1.aa, 1.bb, 1.dd, 1.ii, 1.jj, 1.kk, and 1.ll)
 Ex. A (Proof of payments). Giving Applicant the benefit of a doubt, and given the ultimate disposition of      8
this decision, copies of money orders were accepted as evidence that payments were extended.  It is noted,
however, that such evidence does not actually show that payments were received, accepted, and applied to
the balances at issue.
 Ex. B (Better Business Bureau dispute and related paperwork, Nov. 2010).      9
3
Applicant started working with a credit repair company in 2009. The company
told her not to contact or speak with any of her creditors, instructing her to direct any
inquiries directly to it. It declined to pursue debt settlement on her delinquent accounts,
an issue previously discussed as an option. It told her where to direct payments, but did
not tell her for what accounts payments were being made. Applicant began to suspect
the company was conducting some sort of scheme.  .She filed a complaint with the3
Federal Trade Commission and stopped working with the company. She has not since
heard from the company regarding the payments she made to purported creditors.
In about July 2009,  a friend referred Applicant to a noted law firm that offers a4
credit repair service. She discovered that her prior credit repair company had not
effectuated any payments to her creditors. Declining bankruptcy as an option, she
enrolled in the law firm’s credit repair service in July or August 2009.  The service5
explained to her the essentials of maintaining good credit and methods for tackling her
delinquent debts. It included credit counseling.  With its guidance, she has been6
working to address the debts noted in the SOR.
At issue in the SOR are the following:7
1.a – $3,138 collection account for debt owed to former residential apartment –
Applicant showed three payments on this debt in the amounts of $10, $10, and $15 for
November and December 2010.  8
1.b – $8,703 collection account for debt owed to educational entity – Applicant showed
that she filed a complaint regarding the creditor with the Better Business Bureau
concerning a disputed post-program balance.9
 Ex. C (Better Business Bureau dispute, Dec. 2010).      10
 Exs. D (Undated letter and proof of payments).      11
 Ex. E and Ex. F (Letter, dated Dec. 10, 2010).      12
 Tr. 82.      13
 Tr. 85; Ex. G (Credit Counseling Service report, dated Jan. 15, 2011) at 1.      14
 Tr. 87-89; Ex. G, supra, note 14.      15
 Tr. 90; Ex. G, supra, note 14.      16
 Id.      17
 Tr. 92; Ex. H (Proof of payments). Evidence of a third nominal payment was included in the Response      18
to the SOR.
4
1.c – $320 collection account for telecommunications service – Applicant showed that
she filed a complaint regarding the creditor with the Better Business Bureau concerning
this post-service cancellation balance.10
1.d – $3,120 collection account for apartment rental balance – Applicant cumulatively
paid $35 to this creditor and notified it of her ill health, noting that “if I am able to send
more I will.”  11
1.e; 1.f – Two $50 medical collection balances – Applicant filed a complaint with the
Better Business Bureau regarding these alleged balances.12
1.g – $110 collection account for telecommunications entity – Applicant unsure whether
this is her account and is seeking validation of the debt.  It has been disputed by her13
credit repair service.14
1.h – $70 medical collection balance – Currently in dispute.15
1.i – $1,016 collection account for same telecommunications entity noted in 1.g, above
– This account entry was successfully disputed.     16
1.j – $178 collection account for telecommunications service – This account was
successfully disputed.  17
1.k – $2,046 collection account for apartment building balance – Applicant showed that
she made two payments amounting to $25 between November and December 2010,
and stated that the debt is now in repayment.18
 Tr. 92-93; Ex. G, supra, note 14.      19
  Tr. 93-95; Ex. G, supra, note 14.      20
 Tr. 96; Ex. I (Better Business Bureau dispute, Dec. 2010).      21
 Ex. J (Better Business Bureau dispute, Dec. 2010).      22
 Tr. 98.      23
 Tr. 102-105.      24
 Tr. 102-109; Ex. K (Correspondence, dated Nov. 8, 2010).      25
 Tr. 111.      26
5
1.l – $140 delinquent medical account – This entry was disputed by Applicant’s credit
repair service. It has been successfully disputed and deleted by at least one of the
three leading credit reporting bureaus.19
1.m – $132 collection account for the same telecommunications service noted in 1.g
and 1.i – This entry was successfully disputed by Applicant’s credit repair service and it
has been deleted from her credit report.20
1.n – $420 collection account for telecommunications service – Applicant stated that
she had an unacceptable level of Internet service with this provider. She has lodged a
complaint with the Better Business Bureau regarding this alleged balance.21
1.o – $120 utility account charge-off – Applicant contacted this creditor and was told
that it did not have a record of her having an account or balance. She has disputed the
debt with the Better Business Bureau.  It was also put into dispute by her credit repair22
service with the credit reporting bureaus.23
1.p – $125 collection account for a clothing merchant – Applicant noted that this
account is no longer entered on her credit report. She stated that she has spoken with
the creditor and been told she has no balance owed.   There is no documentary24
evidence indicating that the account was satisfied or the original credit report entry was
erroneous.
1.q – $3,799 collection account for educational services – This entry was deleted from
Applicant’s credit report.  Applicant is also working with a state attorney general’s office25
regarding possibly irregular business practices by the underlying creditor.
1.r – $78 collection account for the same telecommunications service noted in 1.g, 1.i,
and 1.m – To the Government’s satisfaction, this account was paid in full and it has
been deleted from Applicant’s credit report.  26
1.s – $77 collection account for book club – Applicant offered no direct evidence
indicating that this balance was paid. However, she provided documentation showing
 Tr. 112-115; Ex. L (Form letter).      27
 Tr. 118-121.      28
 Tr. 122.      29
 Ex. M (Proof of payments).      30
 Tr. 123.      31
 Ex. N (Proof of payments).      32
 Tr. 124-125.      33
 Tr. 126-127.      34
 Tr. 128.      35
6
that she is currently a member of the book club, and she testified that this entry is being
disputed.27
1.t – $667 collection account – Applicant noted that this entry from 2008 is no longer on
her credit report and stated that it was deleted after dispute by her credit repair
service.  The reason for its deletion after dispute is unknown.28
1.u – $500 medical collection account – Applicant paid $50 plus $10 to $15 in fees on
this balance before she answered the SOR.  She provided evidence of $25 paid29
between November and December 2010.  She intends to pay more on the balance30
when she can.
1.v – $100 collection account – Applicant does not recognize this account entry. Her
credit repair service is currently disputing this account entry.  31
1.w – $176 collection action for telecommunications entity – Applicant paid a cumulative
amount of $35 on this debt between November and December 2010.  32
1.x – $1,413 collection account – Applicant does not recognize this creditor. This entry
will be disputed by her credit repair service.33
1.y – $89 collection account for utility service – Applicant previously paid $10 on this
account, evidence of which was remitted with her Response to the SOR. 
1.z – $806 collection account for utility service – Applicant is trying to discover the origin
of this debt.34
1.aa – $766 collection account – Applicant is trying to discover the origin of this debt.35
 Tr. 133-134.      36
 Tr. 135; Ex. G, supra, note 14.      37
 Tr. 135-136.      38
 Tr. 136-137; Ex. G, supra, note 14.      39
 Tr. 138-139; Ex. G, supra, note 14.       40
 Id.      41
 Tr. 140.      42
 Tr. 139.      43
 Tr. 142.      44
7
1.bb – $107 collection account for returned check – This entry is no longer on
Applicant’s credit report. The basis for its removal is unclear. She does not recollect the
2003 check at issue.  36
1.cc – $216 collection account for telecommunications service – This entry was
disputed and deleted from Applicant’s credit report.37
1.dd – $140 medical collection account – Applicant is unaware as to the origin of this
alleged debt.38
1.ee; 1.ff – $160 and $57   collection account for the same telecommunications service
noted in 1.g, 1.i, 1.m, and 1.r – These entries were disputed by Applicant’s credit repair
service. The former has been successfully disputed and deleted from her credit report,
while latter is still in dispute.39
1.gg – $135 collection account – Applicant is unaware of the origin of this alleged debt.
It is being disputed by Applicant’s credit repair service. They are awaiting the results of
that dispute.40
1.hh – $134 collection account – Applicant is unaware of the origin of this alleged debt.
It is being disputed by Applicant’s credit repair service. They are awaiting the results of
that dispute.41
1.ii – $3,013 charge-off account – This account no longer appears on Applicant’s credit
report. Applicant concedes that she had an account with this provider about six years
ago, and that she never paid off the balance then owed.  She contacted the creditor to42
request validation of any balance owed. She is awaiting a response from the creditor.43
1.jj – $97 collection account for book club balance – Applicant is unaware of the origin
of this entry. It is currently being disputed.44
 Tr. 143; Ex. G, supra, note 14.       45
 Tr. 144.      46
 Tr. 39.      47
 Tr. 154-155.      48
 Tr. 155.      49
 Tr. 156.      50
8
1.kk – $114 collection account for utility service – Applicant does not recall having had
service from this provider. The issue is poised for dispute by Applicant’s credit repair
service.45
1.ll – $101 collection account for telecommunication service – Applicant denies having
had service with this provide and is no longer on her credit report. It was not one of the
accounts disputed by Applicant’s credit repair service. She does not know the current
status of the alleged debt.46
As noted, the majority of the debts at issue originated in the early 2000s. Of
those account entries that were successfully deleted through dispute, there is no
documentary evidence establishing the basis for the dispute. Consequently, it is unclear
which, if any, were deleted because they were over seven years old.
 Currently, Applicant has steady employment and earns approximately $45,000 a
year. She pays about $1,000 a month in rent and approximately $600 a month in
utilities. She does not contribute to a 401(k) plan through her employer. While money is
tight, she is hoping to find less expensive accommodations that could help her save
more money. She stated that she is putting aside money to make progress on her
debts.  Any vacations are generally limited to visiting family in a nearby state. Applicant47
acknowledges that she has been unable to make larger payments on those account
balances on which she has recently made payments, citing to her most recent surgery,
time off for recuperation, and her status as a contractor.  She also notes that her48
progress has been impeded since 2003 because of her erratic employment and health
issues.  Given her present circumstances, Applicant understands she has much work49
to do regarding her finances. She noted, “I’m still trying to fix the problem. It’s going to
take time. I don’t expect it to magically [disappear] overnight. . . I am trying to remedy
the situation and not aggravate it and make it worse.”50
.
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
 See also ISCR Case No. 94-1075 at 3-4 (App. Bd. Aug. 10, 1995).      51
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      52
 Id.      53
 Id.      54
9
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
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 a51
preponderance of evidence. The ultimate burden of persuasion is on the applicant.  52
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 access53
to sensitive information must be resolved in favor of protecting such sensitive
information.54
Based upon 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.      55
 Id.      56
10
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.”  It55
also states that “an individual who is financially overextended is at risk of having to
engage in illegal acts to generate funds.”  Here, the evidence shows that Applicant has56
38 delinquent debts reflected on her credit reports. Many of those debts are very old.
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) apply. With such conditions raised, it is left to Applicant to overcome the
case against her and mitigate security concerns. 
The debts at issue are multiple in number, have long been neglected, and
remain largely unpaid. Although Applicant stated that she is currently living within her
income, she conceded that her finances remain extremely tight. There is no clear
evidence that her financial situation will soon improve and Applicant concedes her
situation will not improve “overnight.” Moreover, while temporarily postponed, it appears
probable that she may soon require a follow-up to the same surgical procedure that first
led her into financial distress. 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) does not apply. 
Multiple factors have adversely affected Applicant’s handling of her finances
since the early 2000s. Multiple moves over the past decade appear to have vexed her
efforts at maintaining contact with her creditors. While this factor was clearly within her
control, she also has had several genuine health issues, at least one of which
necessitated surgery and a protracted recovery period. Moreover, Applicant buys
multiple prescription medications each month. She has experienced multiple periods of
unemployment, one of which occurred in the early 2000s and was for a significant
period. She was recently told by her doctor that another surgery is advised for the near
future. Applicant has postponed this corrective procedure because of her work
responsibilities and her current financial situation. Although there is no documentary
evidence showing that Applicant tried to maintain contact with her creditors over the
years, evidence of which would help demonstrate responsible behavior under the
circumstances, or sought financial counseling at the height of her financial distress,
such factors are sufficient to raise. 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).
 Applicant also admitted the debt at 1.ll for approximately $3,013, but has yet to initiate payments on that      57
debt. Consequently, less than $200 has been applied to approximately $12,100 of acknowledged delinquent
debt over the past few years.
11
Applicant is currently enrolled with a law firm’s credit repair service. That service
includes credit counseling, although there is no evidence that it also included such
helpful services as the development of a working budget or a strategy for paying off
admitted debt. She did, however, provide evidence that the service’s efforts included
the dispute of a number of entries on her credit report. While it is unclear how many
such entries were successfully disputed and removed due to age versus the credit
bureaus’ inability to validate a debt, progress has been made in cleaning up her credit
report. To the limited extent that the service’s efforts have helped Applicant dispute
entries on her credit report, 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) applies. 
Of the 38 debts at issue, Applicant showed recent payments amounting to only
$165 on six admitted debts amounting to approximately $9,079.  Due to recent dispute57
efforts by her credit repair service, however, nine accounts have been successfully
disputed (1,i, 1.j, 1.l, 1.m, 1,q, 1.r, 1.t, 1.cc, and 1,ee) and nine are pending dispute
resolution (1.g, 1.h, 1.o, 1.u, 1.v, 1.x, 1.y, 1.ff, 1.gg, and 1.hh). In addition, five
complaints have been filed with the Better Business Bureau regarding six accounts
(1.b, 1.c, 1.e, 1.f, 1.n, and 1.o). The status of ten alleged accounts, amounting to
approximately $5,350, remains unresolved and largely unaddressed (1.p, 1.s, 1.z, 1.aa,
1.bb, 1.dd, 1.ii, 1.jj, 1.kk, and 1.ll). 
Of the nominal payments made on six of the acknowledged debts, most of those
payments were made months after the issuance of the SOR. There is scant
documentary evidence of payments or action on any of the debts at issue prior to
Applicant’s receipt of the SOR. The recent and haphazard payments that were made do
not reflect adherence to an established repayment plan or clear strategy, nor is there
evidence that Applicant has adopted one. While it is recognized Applicant’s finances
are lean at present, these erratic payments have been nominal, especially in light of the
balances at issue. Moreover, there is no documentary evidence showing that her
creditors have accepted her payments as part of a mutually adopted debt repayment
plan or that she has maintained regular correspondence with her creditors about her
position. Overall, however, it is recognized that Applicant’s credit repair service has
made significant strides in reducing the number of debts at issue. In light of these facts,
FC MC AG ¶ 20(d), (the individual initiated a good-faith effort to repay overdue creditors
or otherwise resolve debts) applies to a limited extent. None of the other FC MCs apply.
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
12
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 mature woman who has been plagued by medical issues and
periods of unemployment since 2000. She is well-educated, having earned a bachelor’s
degree and commenced work on a master’s degree. She is single and has no children.
Applicant makes under $50,000. Multiple moves over the past decade seem to have
undermined reciprocal efforts between creditors and Applicant to maintain uninterrupted
contact. This fact appears to have contributed to her passive acquisition and ultimate
neglect of delinquent debt, and her inability to identify some past creditors whose
balances are now in collection with third-party entities.  
Applicant raised mitigating factors with regard to her acquisition of debt, and
facts tending to explain why much of her debt remains existent today. Her recent
reliance on a credit counseling service has proved to be fruitful in clearing her credit
report of several old and unknown or unverifiable account entries. What remains
troublesome is her lack of a holistic plan for repaying her acknowledged debts in a way
that is more meaningful than the nominal, randomly administered payments she has
made, the vast majority of which were made well after the September 2010 SOR was
issued. As a result, the evidence basically reflects a twelfth-hour attempt to formulate a
record that shows some element of progress has been made. 
The AG does not require that an Applicant satisfy all of one’s debts, only that
there be evidence that a reasonable plan to address one’s debts has been devised, and
that there is evidence that such a plan is being executed. Here, the evidence does not
show that such a plan is being functionally executed, and the evidence does not show
that Applicant’s debts are presently under control. Moreover, while Applicant testified
that she is setting money aside to apply to her debts, there is insufficient evidence
showing that she truly has the resources to do so. Further, in the face of limited income
from her current position, there is scant evidence showing that Applicant has
successfully either made cuts in her expenses or undertaken profitable secondary
employment that might raise her ability to address her debt.
Applicant’s debts are significantly delinquent and there is scant documentary
evidence showing any early efforts to work with her creditors. Nor is there evidence of
progress on her delinquent debts during her comparably stable period of employment
between 2004 and 2009. The evidence shows her first meaningful steps to address her
debts occurred after the issuance of the September 2010 SOR. This late start helped
undermine her current effort to show that her aged debts are now under control.
However, once the credit counseling service completes its dispute and validation
process and the true extent of Applicant’s debt is more apparent, she should be poised
for devising a systematic plan for addressing her debt with the help of financial
counseling. At present, however, the debts at issue are exceptionally numerous and her
income highly limited. Without more significant indicators reflecting that a reasonable
debt repayment plan has been devised and implemented, and lacking evidence that her
13
debts are under control, I find that Applicant failed to meet her burden in mitigating
financial considerations security concerns. 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, Guideline F: AGAINST APPLICANT
Subparagraphs 1.a-1.ll: Against Applicant
Conclusion
In light of all of the circumstances presented by the record in this case, it is not
clearly consistent with national interest to grant Applicant a security clearance.
Clearance denied.
ARTHUR E. MARSHALL, JR.
Administrative Judge