1
 
                                                             
                           DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
)       ISCR Case No. 11-01991
)
Applicant for Security Clearance )
Appearances
For Government: Alison O’Connell, Esquire, Department Counsel
For Applicant: Alexander M. Laughlin, Esquire
______________
Decision
______________
HENRY, Mary E., Administrative Judge:
Based upon a review of the pleadings, exhibits, and testimony, Applicant’s
eligibility for access to classified information is granted.
Statement of the Case
Applicant signed an Electronic Questionnaire for Investigations Processing (e-
QIP) on September 27, 2010. The Defense Office of Hearings and Appeals (DOHA)
issued Applicant a Statement of Reasons (SOR) on December 22, 2011, detailing
security concerns under Guideline F, financial considerations. 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 (AG) implemented on September 1, 2006. 
 
W hen  SOR allegations are controverted, the Government bears the burden of producing evidence sufficient1
to prove controverted allegations. Directive, ¶ E3.1.14. “That burden has two components. First, the
Government must establish by substantial evidence that the facts and events alleged in the SOR indeed took
place. Second, the Government must establish a nexus between the existence of the established facts and
events and a legitimate security concern.” See ISCR Case No. 07-18525 at 4 (App. Bd. Feb. 18, 2009),
(concurring and dissenting, in part) (citations omitted). The guidelines presume a nexus or rational connection
between proven conduct under any of the criteria listed therein and an applicant’s security suitability. See
ISCR Case No. 08-06605 at 3 (App. Bd. Feb. 4, 2010); ISCR Case No. 08-07290 at 2 (App. Bd. Nov. 17,
2009).
GE 1; Tr. 27-30.2
2
Applicant received the SOR on January 3, 2012, which he answered on February
3, 2012. Applicant retained counsel and requested a hearing before an administrative
judge. DOHA received the request, and Department Counsel was prepared to proceed
on February 15, 2012. I received the case assignment on February 21, 2012. DOHA
issued a Notice of Hearing on March 6, 2012, and I convened the hearing as scheduled
on March 29, 2012. The Government offered exhibits marked as GE 1 through GE 7,
which were received and admitted into evidence without objection. Applicant testified.
He submitted exhibits marked as AE A through AE N, which were received and
admitted into evidence without objection. The record closed on March 29, 2012. DOHA
received the hearing transcript (Tr.) on April 6, 2012.
Findings of Fact
In his Answer to the SOR, Applicant admitted the factual allegations in ¶ 1.a of
the SOR. His admissions are incorporated herein as findings of fact. He denied the
factual allegations in ¶ 1.b of the SOR.  He also provided additional information to1
support his request for eligibility for a security clearance. After a complete and thorough
review of the evidence of record, I make the following additional findings of fact.  
Applicant, who is 31 years old, works as a principal engineer for a Department of
Defense contractor. He began his employment with this company in 2004 as an
associate engineer. The company promoted him in 2006 to engineer, in 2008 to senior
engineer, and to his present position in 2011.2
Applicant’s direct supervisor, the senior security analyst, and a co-worker
submitted letters of recommendation. His supervisor indicated Applicant’s work had
exceeded all expectations since 2004. His superior performance led to his quick
promotions. His company and its customers benefit from his technical contributions and
capabilities and his personal manner. Applicant has held a security clearance for seven
years. His security analyst states that Applicant views security seriously. He works in a
classified environment daily and has not violated security procedures. He is entrusted
with combinations to program closed areas and is one of five people authorized to
perform trusted downloads for the program. He takes his duty to protect national
security seriously. His co-worker knows him at work and outside of work. He trusts
Applicant implicitly and indicates that Applicant never cuts corners, fails to complete
AE B - AE D.3
GE 3 - GE 7; Tr. 52, 67-68, 74-75.4
GE 2; Tr. 36-41.5
3
work, and honors his commitments. These individuals do not indicate any knowledge of
his financial problems.   3
Applicant received a bachelor’s degree in aerospace engineering and a master’s
degree in business administration. He and his wife married in April 2007. He has a 15-
month-old son.
Applicant earns $6,464 a month in gross income and receives $3,523 a month in
net income. His wife earns approximately $5,467 a month in gross income plus
occasional overtime pay. Her monthly net income is approximately $4,400. Their total
net household monthly income is approximately $7,923. Their total monthly expenses
are approximately $5,060. Applicant estimates their monthly miscellaneous expenses at
$1,000. These periodic expenses include house maintenance, entertainment, eating
out, haircuts, car repairs, and other necessary expenditures for daily living. His monthly
disposable income is approximately $1,863. He owns two 2006 cars and a 2005
motorcycle debt free. He pays his credit card bills in full each month. The credit reports
of record show that he pays his bills and has no outstanding debt other than the two
mortgage debts listed in the SOR.   4
In 2006, Applicant decided to purchase a house. He pre-qualified for a mortgage
up to $350,000. Applicant purchased a single-family house on less than two and one-
half acres of land for $207,000 because he was concerned about his ability to pay a
higher monthly mortgage payment. His financed the house through the builder with a
$166,000 first mortgage at a 6.5% fixed rate and a $41,500 second mortgage at 8.25%
fixed rate for 15 years, but amortized over 30 years. At the end of 15 years, there would
be a balloon payment due on the second mortgage. His monthly payments plus
homeowners dues totaled approximately $1,750.  His girlfriend, now wife, moved into
the house a few months after he moved into the house.5
By June 2008, Applicant recognized a problem with housing on his street. Of the 20
houses owner occupied in 2006, only four or five were still owner occupied. He
determined from two internet sites that the value of his house had declined to $150,000
by 2008. He spoke with his financial advisor, who recommended he abandon the
property, and with a real estate lawyer, who told him about the state’s anti-deficiency
statutes. After learning this information, he started calling his mortgage lender once a
month to discuss his options. When he called the mortgage lender, his call was placed
on hold for 30 to 45 minutes before he spoke with a person. His call was transferred two
or three times before he could speak with a person. When he finally spoke with the right
person, he was told that since his mortgage payment was current, he had no options. In
GE 2; Tr. 41-45, 71-72. 6
GE 2; Tr. 45-47.7
For the mortgage lender to agree to a short-sale or a deed-in-lieu of foreclosure, a person must stop paying8
their monthly mortgage payments.
Tr. 47-49, 50-51, 65-66.9
Applicant testified that to his knowledge, when the bank reclaimed his house, it put the value of the loan in10
the foreclosure documents, but that no money was actually paid. He also indicated that the special warranty
deed was to prevent flipping of houses. Tr. 66, 70-71.
4
2009, he spoke with a real estate broker about selling his house. The real estate broker
advised him that it would be difficult to find a buyer for his property.   6
Applicant and his wife decided to purchase another property closer to his work
and larger than the above property. He again received loan pre-qualification, this time in
the amount of $450,000. He and his wife found another house, which they purchased
for $300,000. He chose not to purchase a more expensive house, because he wanted
to pay his monthly payment. He and his wife moved into their new home in January
2010.  7
Applicant stopped paying his monthly mortgage payment on his first home in
January 2010 because the value of the house had decreased more than 50%. He
acknowledged that he decided not to honor his contract on this property. After he
stopped his payments, he eventually spoke with his mortgage lender, after several
failed attempts. When he asked about his options, the lender told him that his only
option was foreclosure. The lender did not suggest a short-sale or deed-in-lieu of
foreclosure. Applicant decided not to rent his first house.  He continued to pay his8
homeowners association fees and his utility bills. He also maintained the yard and the
house until it was sold.9
On May 12, 2010, the notice of trustee’s sale was sent for Applicant’s property.
The trustee sold this property on August 11, 2010 for $167,000 to a mortgage
association. On October 29, 2010, the mortgage association, as the grantor, conveyed
this property by a special warranty deed for $10 to an investment company, the grantee.
Under the special warranty deed, the grantor warranted that it has not done or suffered
anything to encumber the property, and the grantee was prohibited from conveying the
property for a sales price of greater than $81,840 for three months.10
Applicant has never received any documents from the mortgage lender
requesting him to pay a deficiency balance. He has never received a 1099 form from
the mortgage lender nor has the Internal Revenue Service (IRS), even though Applicant
believes the bank had an obligation to send the form. The November 5, 2010 credit
report reflects that the mortgage lender for the first mortgage reclaimed the property to
GE 4; Tr. 66-67, 75-76.11
Response to SOR; AE J.12
5
settle a defaulted mortgage and that the balance on the mortgage was zero. The
second mortgage is listed as a charge off with a zero balance.11
Applicant’s counsel provided a copy of the state anti-deficiency statute, which
states as follows:
33-729 Purchase money mortgage; limitation of liability
A. Except as provided in subsection B, if a mortgage is given to secure the
payment of the balance of the purchase price, or to secure a loan to pay
all or part of the purchase price, of a parcel of real property of two and
one-half acres or less which is limited to and utilized for either a single
one-family or single two-family dwelling, the lien of judgment in an action
to foreclose such mortgage shall not extend to any other property of the
judgment debtor, nor may general execution be issued against the
judgment debtor to enforce such judgment, and if the proceeds of the
mortgaged real property sold under special execution are insufficient to
satisfy the judgment, the judgment may not otherwise be satisfied out of
other property of the judgment debtor, notwithstanding any agreement to
the contrary.
B. The balance due on a mortgage foreclosure judgment after sale of the
mortgaged property shall constitute a lien against other property of the
judgment debtor, general execution may be issued thereon, and the
judgment may be otherwise satisfied out of other property of the judgment
debtor, if the court determines, after sale upon special execution and upon
written application and such notice to the judgment debtor as the court
may require, that the sale price was less than the amount of the judgment
because of diminution in the value of such real property while such
property was in the ownership, possession, or control of the judgment
debtor because of voluntary waste committed or permitted by the
judgment debtor, not to exceed the amount of diminution in value as
determined by the court.12
Applicant’s counsel also provided a copy of the state statute 33-814 which
outlines the process for a trustee to recover a deficiency judgement. This statute
contains two exceptions for recovery of a deficiency judgment. Under one exception,
when a trust property of two and one-half acres or less which is limited to and utilized
for either a single one-family or a single two-family dwelling is sold through the trustee’s
AE K.13
Id.; Response to SOR.14
See also AE L.15
AE N.16
6
power of sale, then no action may be maintained to recover any difference between the
amount of the sale and the amount of indebtedness.   13
State law provides that the mortgage loan given to Applicant is a nonrecourse
loan. The Trustee’s Deed Upon Sale indicates that Applicant’s property sold on August
11, 2010. This document does not reflect any diminution in the value of this property
because of waste, as defined in the statute, by Applicant. He continued to maintain the
property until its sale. The final sale document does not show that Applicant owes any
money due to waste of the property, and under state law, he does not have a deficiency
balance.14
Congress passed the Mortgage Forgiveness Debt Relief Act of 2007, then later
extended its provisions through calendar year 2012. This federal statute allows
taxpayers to exclude income from the discharge of debt on their principal residence on
their taxes for the year in which the debt was cancelled. The statute also provides some
exceptions on what is taxable income from cancelled debt, and specifically identified
non-recourse loans as non-taxable income. A non-recourse loan is a loan for which the
lender’s only remedy when default occurs is to repossess the property financed or used
as collateral. The lender has no further right to pursue the debtor personally for any
balance due. See www.irs.gov/individuals/article/0,,id=179414,00.html (The Mortgage
Forgiveness Debt Relief Act and Debt Cancellation). Property sold at a Trustee’s sale is
treated for tax purposes as a sale of the residence, which requires the mortgage lender
to issue a 1099-C. The lender should check the box on the form which indicates that the
individual is not personally liable. The lack of liability arises from the state anti-deficiency
statute.  The highest court in his state has also held that the holder of a second15
mortgage is prohibited from suing for monies due on a second mortgage under the
State’s anti-deficiency statute.16
Policies
When evaluating an applicant’s suitability for a security clearance, the
administrative judge must consider the adjudicative guidelines. In addition to brief
introductory explanations for each guideline, the adjudicative guidelines list potentially
disqualifying conditions and mitigating conditions, which are used in evaluating an
applicant’s eligibility for access to classified information.
.
These guidelines are not inflexible rules of law. Instead, recognizing the
complexities of human behavior, these guidelines are applied in conjunction with the
factors listed in the adjudicative process. The administrative judge’s overarching
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adjudicative goal is a fair, impartial, and commonsense decision. According to AG ¶
2(c), the entire process is a conscientious scrutiny of a number of variables known as
the “whole-person concept.” The administrative judge must consider all available,
reliable information about the person, past and present, favorable and unfavorable, in
making a decision.
The protection of the national security is the paramount consideration. AG ¶ 2(b)
requires that “[a]ny doubt concerning personnel being considered for access to
classified information will be resolved in favor of national security.” In reaching this
decision, I have drawn only those conclusions that are reasonable, logical, and based
on the evidence contained in the record.
Under Directive ¶ E3.1.14, the Government must present evidence to establish
controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, 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. . . .” An
applicant has the ultimate burden of persuasion for obtaining a favorable security
decision.
A person who seeks access to classified information enters into a fiduciary
relationship with the Government predicated upon trust and confidence. This
relationship transcends normal duty hours and endures throughout off-duty hours. The
Government reposes a high degree of trust and confidence in individuals to whom it
grants access to classified information. Decisions include, by necessity, consideration of
the possible risk an applicant may deliberately or inadvertently fail to protect or
safeguard classified information. Such decisions entail a certain degree of legally
permissible extrapolation as to potential, rather than actual, risk of compromise of
classified information.
 
Section 7 of Executive Order 10865 provides that decisions shall be “in terms of
the national interest and shall in no sense be a determination as to the loyalty of the
applicant concerned.” See also EO 12968, Section 3.1(b) (listing multiple prerequisites
for access to classified or sensitive information).  
Analysis
Guideline F, Financial Considerations
The security concern relating to the guideline for Financial Considerations is set
out in AG & 18:      
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
8
protect classified information. An individual who is financially overextended
is at risk of having to engage in illegal acts to generate funds. 
AG ¶ 19 describes the disqualifying conditions that could raise security concerns.
I have considered all the conditions, and the following are potentially applicable: 
(a) inability or unwillingness to satisfy debts. 
Applicant decided not to pay the mortgages on his first home after the property
value declined, and he had purchased a second home. This disqualifying condition
applies.
The Financial Considerations guideline also includes examples of conditions that
can mitigate security concerns. I have considered mitigating factors AG ¶ 20(a) through
20(f), and the following are potentially applicable:
(a) the behavior happened so long ago, was so infrequent, or occurred
under such circumstances that it is unlikely to recur and does not cast
doubt on the individual=s current reliability, trustworthiness, or good
judgment;
(b) the conditions that resulted in the financial problem were largely
beyond the person=s control (e.g., loss of employment, a business
downturn, unexpected medical emergency, or a death, divorce or
separation), and the individual acted responsibly under the circumstances;
(c) the person has received or is receiving counseling for the problem
and/or there are clear indications that the problem is being resolved or is
under control; and
(d) the individual initiated a good-faith effort to repay overdue creditors or
otherwise resolve debts.
Applicant’s delinquent debts are “a continuing course of conduct” under the
Appeal Board’s jurisprudence because he had a large delinquent debt in 2010. See
ISCR Case No. 07-11814 at 3 (App. Bd. Aug. 29, 2008) (citing ISCR Case No. 01-
03695 (App. Bd. Oct. 16, 2002)). Applicant does not receive credit under AG ¶ 20(a)
even though he established that his financial problems “occurred under such
circumstances that [they are] unlikely to recur.” Applicant has resolved his delinquent
SOR debt, and is unlikely Applicant will have delinquent debt in the future.
AG ¶ 20(b) does not apply because Applicant has not shown that his financial
problem arose from circumstances beyond his control. The loss of value in house when
the real estate market declined is a factor beyond his control. However, he paid his
mortgage and had sufficient funds to do so despite the decline in the market value of his
house. No other factors beyond his control occurred to create his financial problem.
The Appeal Board held that a 1099-C is one way to show there is clear evidence that the state law has17
extinguished the debt. See ISCR Case No. 10-01978. The 1099-C is a tax form which provides information
to the Internal Revenue Service on whether taxable income arose from the sale of a property. In this case,
state law makes it clear that Applicant does not owe any money on her mortgage loan.
9
Applicant’s mortgage debt on his property is resolved by operation of law. The
state anti-deficiency statute prohibits Applicant’s mortgage lender from seeking to
recover the more than $100,000 balance due on his first and second mortgage loans
after foreclosure. Under state law, the loans on residence are non-recourse loans.
Federal law requires the mortgage lender to issue a 1099-C, a tax form, which shows
that no taxable income arose from the sale of his property, but the lender has not done
so. Applicant has no control over the failure of the lender to issue a document required
by law.  In addition, the November 5, 2010 credit report shows a zero balance on the17
primary mortgage after the lender reclaimed the property to settle a defaulted mortgage.
Applicant pays his other bills and his finances are under control. AG ¶ 20(c) applies.
Applicant has not made a good-faith effort to pay his mortgage debts. AG ¶ 20(d)
is not applicable. AG ¶¶ 20(e) and 20(f) are also not applicable in this case.
Whole-Person Concept
Under the whole-person concept, the administrative judge must evaluate an
applicant’s eligibility for a security clearance by considering the totality of an applicant’s
conduct and all relevant circumstances. The administrative judge should consider the
nine adjudicative process factors listed at AG ¶ 2(a):
(1) the nature, extent, and seriousness of the conduct; (2) the
circumstances surrounding the conduct, to include knowledgeable
participation; (3) the frequency and recency of the conduct; (4) the
individual’s age and maturity at the time of the conduct; (5) the extent to
which participation is voluntary; (6) the presence or absence of
rehabilitation and other permanent behavioral changes; (7) the motivation
for the conduct; (8) the potential for pressure, coercion, exploitation, or
duress; and (9) the likelihood of continuation or recurrence. 
Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a
security clearance must be an overall commonsense judgment based upon careful
consideration of the guidelines and the whole-person concept. The decision to grant or
deny a security clearance requires a careful weighing of all relevant factors, both
favorable and unfavorable. In so doing, an administrative judge must review all the
evidence of record, not a single item in isolation, to determine if a security concern is
established and then whether it is mitigated. A determination of an applicant’s eligibility
for a security clearance should not be made as punishment for specific past conduct,
In its December 28, 2011 decision in ISCR CASE No. 10-04405, the Appeal Board provided guidance for18
administrative judges when doing a “whole-person” analysis. The Appeal Board stated:
. . . A whole-person analysis entails an examination of the entirety of the record evidence in
relation to the security concerns raised in a SOR.  See, e.g., ISCR Case No. 02-28891 at 4
(App. Bd. Apr. 22, 2004). Although the Directive lists certain factors which are normally
associated with a whole-person analysis, these are not exhaustive. See, e.g., ISCR Case No.
04-00540 at 7 (App. Bd. Jan. 5, 2007). A Judge may conclude, as a result of his whole-
person analysis, that an applicant is a person of good character. However, that analysis
requires the Judge to proceed with the question of whether there is a nexus between an
applicant’s evidence of good character and the applicant’s claim that he has m itigated the
security concerns in his case. See, e.g., ISCR Case No. 04-00109 at 4-5 (App. Bd. Jul. 13,
2006). In a Guideline F case, a whole-person analysis would require a Judge to consider
whether an applicant’s mitigation evidence bears a rational connection to a conclusion that
the applicant would resist those pressures that are a reasonably foreseeable from his
financial delinquencies. See Motor Vehicle Mfrs. Ass’n of the United States v. State Farm
Mut. Auto Ins. Co., 463 U.S. 29. 43 (1983) Viewed in this way, a favorable whole-person
analysis would mean that the Judge has found such a nexus and that applicant should be
cleared.
10
but on a reasonable and careful evaluation of all the evidence of record to decide if a
nexus exists between established facts and a legitimate security concern.  18
The evidence in support of granting a security clearance to Applicant under the
whole-person concept is more substantial than the evidence in support of denial. In
reaching a conclusion, I considered the potentially disqualifying and mitigating
conditions in light of all the facts and circumstances surrounding this case. When the
market value of his first home declined by more than 50% over the first three years of
ownership, Applicant made a decision to purchase a new house and stop paying the
mortgage on his first house. After moving from his first house, he continued to maintain
the property, which included keeping up the lawn, paying his homeowners fees and
paying the utilities, duties required under the Deed of Trust. He continued to spend time
at the house, which allowed him to determine if unanticipated damage or problems with
the house had arisen. Both Applicant and the mortgage lender benefitted from his
continued maintenance of the house.
Applicant timely paid his mortgage each and every month until January 2010.
Before he decided to stop paying his mortgage, he made regular attempts to discuss his
options with the  mortgage lender. When he finally spoke with a representative, he was
told he had no options because he paid his mortgage every month.
Applicant spoke with his financial advisor, who told him his best course of action
was to abandon the house, and with a lawyer, who gave him advice about his legal
liability should he abandon the house. In 2009, he approached a realtor about selling
the house. The realtor told him that it would be difficult to find a buyer. DOHA cases
reflect that since Applicant talked with the realtor in 2009 and defaulted on his mortgage
in 2010, short-sales have increasingly become a way to resolve mortgages issues with
properties devalued in the economic decline. Mortgage lenders and banks refused to
employ short-sales and deed-in-lieu of foreclosure as a mechanism to resolve defaulted
11
mortgages for several years, but more recently have decided that this option is
preferable. His mortgage lender failed to discuss this option with Applicant, telling him
his only option was to proceed with foreclosure. Based on all the information and advice
he had received, he decided to stop paying his mortgage. Renting the property
produces income, but it also is fraught with problems such as nonpaying tenants,
particularly in poor economic times, and property damage, which at times can cost
thousands of dollars to repair. With all the advice given to him, not one of these
individuals or the Applicant considered his security clearance an issue, thus he did not
receive any advice on the impact his decision and their advice would have on his
security clearance. Applicant carefully considered his long-term goals and the negative
financial impact of paying for his house that had depreciated more than 50% in value.
He made an informed decision, not a careless or haphazard decision, to abandon his
house. Essentially, he made a business decision which, in security clearance law raises
questions of poor judgment and lack of responsibility to honor once’s contracts.
Applicant owns his cars. He timely pays his current mortgage, utility bills, credit
card bills, and all other bills every month and always has. He does not have excessive
debt nor has he financially over-extended himself. Although he pre-qualified for a higher
mortgage twice, he always chose to purchase a less costly house as an assurance to
himself that he could pay the mortgage. In making these decisions, he showed
prudence and reasonable judgment. As verified by his employer’s security analyst, he
has never violated the rules and procedures for handling classified information in his
seven years of working at his current job. His manager praises his work ethic, but does
not show an indication that he is aware of Applicant’s decision to breach his purchase
contract on his house. Applicant listed his foreclosure on his e-QIP, and has been
forthright open about his decision. Given his overall financial track record and his
outstanding work record, Applicant’s decision on his mortgage cannot be used to coerce
or force him to reveal classified information. His decision on his mortgage does raise a
question about how he exercises his judgment and his ability to act responsibility. He
received advice from a financial advisor, a realtor, and a lawyer, which came from their
experiences in their professions and would be considered reasonable and accurate
professional advice under these circumstances. Given his decision to walk away from
his contract when he could have remained in the house and paid the mortgage, the
issue becomes will he make poor decisions about or act irresponsibly when handling
classified information. He did not make the decision to walk away from his first home
mortgage impulsively or in haste; rather, he sought guidance and gathered information
on how to resolve the issue he believed he had. He sought help from the mortgage
lender for assistance, but, as mentioned previously, received none. Having considered
both his bad decision to walk away from his contractual obligations, his overall prudent
fiscal management, and his good character disclosed in this record, I find that he has
established the requisite nexus showing that he would exercise good judgment in
handling classified information as he has done in the past and not could resist those
Department Counsel argues the Government cannot be sure Applicant will not make the same decision in19
the future under similar circumstances. In light of his overall conservative financial decision making and this
proceeding to deny him a security clearance, an assumption cannot be made that Applicant will make this
same decision in the future.
12
pressures reasonably foreseeable from his foreclosure.  In weighing the all the19
evidence of record, I find that Applicant has mitigated the Government’s security
concerns.
Overall, the record evidence leaves me without questions or doubts as to
Applicant’s eligibility and suitability for a security clearance. For all these reasons, I
conclude Applicant mitigated the security concerns arising from his finances under
Guideline F.
Formal Findings
Formal findings for or against Applicant on the allegations set forth in the SOR,
as required by section E3.1.25 of Enclosure 3 of the Directive, are:
Paragraph 1, Guideline F: FOR APPLICANT
Subparagraph 1.a: For Applicant
Subparagraph 1.b: For Applicant
Conclusion
In light of all of the circumstances presented by the record in this case, it is
clearly consistent with the national interest to grant Applicant eligibility for a security
clearance.  Eligibility for access to classified information is granted.
                                                              
MARY E. HENRY
Administrative Judge