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DEPARTMENT OF DEFENSE 
DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
In the matter of:    ) 
      ) 
                ) ISCR Case No. 11-02004 
     ) 
Applicant for Security Clearance  ) 
 
 
Appearances 
 
For Government: Richard Stevens, Esquire, Department Counsel 
For Applicant: Pro se 
 
 
______________ 
 
Decision 
______________ 
 
 
CREAN, Thomas M., Administrative Judge: 
 
Based on a review of the pleadings, exhibits, and testimony, eligibility for access 
to classified information is granted.  
 
Statement of the Case 
 
On October 5, 2010, Applicant submitted an Electronic Questionnaire for 
Investigations Processing (e-QIP) to obtain a security clearance required for a position 
with a defense contractor. After an investigation conducted by the Office of Personnel 
Management (OPM), the Defense Office of Hearings and Appeals (DOHA) issued 
interrogatories to Applicant to explain potentially disqualifying information in her 
background. After reviewing the results of the background investigation and Applicant's 
responses to the interrogatories, DOHA could not make the preliminary affirmative 
findings required to issue a security clearance. DOHA issued a Statement of Reasons 
(SOR), dated April 23, 2012, detailing security concerns based on Applicant’s finances. 
These actions were 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 
 
 
 
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(January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) 
effective in the Department of Defense on September 1, 2006. Applicant acknowledged 
receipt of the SOR on May 2, 2012. 
 
Applicant answered the SOR on May 15, 2012. She admitted 37 of the 46 
allegations and denied nine (SOR 1.b, 1.e, 1.l, 1.m, 1.t, 1.ff, 1.gg, 1jj, and 1.mm). 
Department Counsel was ready to proceed on June 12, 2012. The case was assigned 
to me on July 18, 2012, and DOHA issued a Notice of Hearing on July 19, 2012, 
scheduling a hearing for August 16, 2012. I convened the hearing as scheduled. The 
Government offered eight exhibits that I marked and admitted into the record without 
objection as Government Exhibits (Gov. Ex.) 1 through 8. Applicant testified, and 
submitted six documents that were marked and admitted into the record without 
objection as Applicant Exhibits (App. Ex.) A through F. I left the record open for 
Applicant to submit additional documents. Applicant timely submitted nine documents, 
which were marked and admitted into the record without objection as Applicant Exhibits 
G through N. Department Counsel had no objection to admission of the documents. 
(Gov. Ex. 9, e-mail, dated September 6, 2012). DOHA received the transcript of the 
hearing (Tr.) on August 29, 2012. 
 
Findings of Fact 
 
After a thorough review of the pleadings, transcript, and exhibits, I make the 
following essential findings of fact.   
 
Applicant is a 43-year-old high school graduate who is employed by a defense 
contractor as a material handling specialist. She married at age 19 in 1988. That 
marriage ended in divorce in 1994. She married again in 1999, and that marriage ended 
in divorce in 2003. She has been cohabitating with an individual since November 2009. 
Applicant has two sons, age 19 and six. Her oldest son has a severe mental health 
issue that requires extensive medical treatment.  
 
Applicant has an extensive work history. Applicant worked in a cotton mill from 
May 1989 until the mill shut down in December 2001. She was unemployed for five 
months from December 2001 until May 2002, when she found employment at an 
automobile manufacture’s parts distribution center. That company downsized and she 
was laid off in October 2003 and was unemployed until February 2004, when she 
started working for a defense contractor in their warehouse. She again experienced a 
downsizing and lay-off in July 2007. She was unemployed from July 2007 until February 
2008, when she started working for another defense contractor in the warehouse. She 
had a long expensive commute for this job so she moved to another part of the state in 
February 2010 for better employment opportunity with a shorter and less expensive 
commute. She started working with her present defense contractor employer in 
February 2010.  
 
 
 
 
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In a four-year period, she had unemployment times of five months, six months, 
five months, and seven months. Approximately half the time in the four years, she was 
unemployed. She always sought employment after being laid off. When not employed, 
Applicant received unemployment compensation of approximately $270 per week. (Tr. 
11-13; Gov. Ex. 1, e-QIP, dated October 5, 2010; Gov. Ex. 2, e-QIP, dated July 12, 
2007; Gov. Ex. 3, Response to Interrogatories, dated August 23, 2011) . 
 
Applicant’s income has varied over time. She and her second husband both 
worked at the cotton mill from their marriage in 1999 until the mill closed in 2001. Their 
combined yearly income was approximately $44,000. Her hourly rate at her next job 
was from $10 to $14, with an approximate yearly salary of only $16,000. Her salary with 
her present employer is approximately $44,210 per year. Her hourly rate is $17, but she 
has significant overtime. Her co-habitant nets about $2,000 per month. They have 
expenses in excess of $3,000 and have monthly discretionary income of approximately 
$400. Applicant has been able to save some money recently and has a few hundred 
dollars in savings. They do not live paycheck to paycheck. (Tr. 28-30, 33-41; Gov. Ex. 5, 
Financial Interrogatory, dated August 23, 2011, at 227) 
 
Credit reports (Gov. Ex. 6, dated August 9, 2006; and Gov. Ex. 7, dated October 
19, 2010; and January 26, 2012), Applicant’s answers to interrogatories (Gov. Ex. 4 and 
Gov. Ex. 5, dated August 23, 2011), and her response to questions from a security 
investigator (Gov. Ex. 3, dated August 23, 2011) enumerate 46 delinquent debts. These 
debts include 25 medical accounts SOR 1.a, 1.b, 1.f, 1.j through 1.n, 1.s, 1.bb through 
1.ee, 1.hh, 1.ii, and 1.kk through 1.tt); five phone accounts (SOR 1.c, 1.h, 1.t, 1.gg, and 
1.jj); four credit accounts (SOR 1.d, 1.q, 1.aa, and 1.ff); five student loan accounts (SOR 
1.g, 1.o, 1.u, 1.w, and 1.x); one utility account (SOR 1.e); one vehicle repossession 
(SOR 1.i); two apartment rent accounts (SOR 1.p, and 1.y); and three cable service 
accounts. Applicant kept meticulous financial records and provided detailed information 
on her debts. She prepared a spreadsheet on all of the SOR debts. (Tr. 11-12, 22-24; 
See Response to SOR, dated May 15, 2012) After the hearing, Applicant presented an 
updated spread sheet on the status of her finances. (App. Ex. G, Spreadsheet, undated)  
 
Applicant started experiencing financial difficulty in 2003. Her oldest son needed 
extensive medical care for his condition that was costing her about $400 to $500 per 
month. Her first priority was to pay the medical expenses so her son could continue 
medical care. She received only sporadic child support from her former husband. He 
stopped all support when their son turned 18 years old. She had an unplanned difficult 
pregnancy in 2005/2006. Some of the medical debts were incurred from this pregnancy. 
She was unable to work and was on bed rest because of the pregnancy-related medical 
problems. During the pregnancy, Applicant had health insurance and most of the debts 
were co-pays.  
 
She incurred additional medical expenses. She was unable to pay bills without 
her income. She had extensive medical problems in February 2010 and February 2011. 
 
 
 
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Both times, she required surgery and hospitalization. The medical bills were mostly paid 
by health insurance. (Tr. 26-29, 72-78) 
 
The medical debt for $60 at SOR 1.a is a co-payment for a neo-natal test. She 
does not believe this debt has been paid. She is making inquiries as to the method of 
paying this debt. (Tr. 41-42) 
 
The medical debt for $58 at SOR 1.b is for a chiropractor Applicant saw during 
the pregnancy. She paid a co-payment and does not know why there is a debt owed. 
She disputed this debt with the doctor even before she left the doctor’s office. (Tr. 42-
44) 
 
The delinquent debt for $43 at 1.c is for a telephone debt from the apartment 
Applicant rented during part of the pregnancy. The apartment was on the second floor. 
She could not climb stairs because of her condition, so she terminated the lease. She 
does not remember paying the final bill and believes this may be that bill. She is 
attempting to make arrangements to pay the debt. (Tr. 44-45) 
 
The delinquent debt for $147 at SOR 1.d is a pay advance Applicant received 
from an employer. She was laid off before the entire amount was repaid. She has paid 
the debt in full. (Tr. 45; App. Ex. K, Moneygram, dated August 22, 2012) 
 
The $85 electric utility bill at SOR 1.e has been paid. The bill originates from an 
apartment Applicant rented with her second husband until 2006. She thought the final 
bill had been paid. When she needed electric service again in 2008 at another 
apartment, she was informed of the debt. She paid the debt so she could get electric 
service. (Tr. 24, 45-46; App. Ex. D, Utility Notice, dated May 23, 2008) 
 
The delinquent debt for $106 at SOR 1.f is another medical bill from her 2006 
pregnancy. She does not remember if she paid the co-pament. She believes the debt is 
still outstanding. (Tr. 46-47) 
 
The delinquent debt for $529 at SOR 1.g is for an on-line course. The school 
claimed Applicant failed the course but Applicant disputed this with the school. The 
school reduced the debt to a quarter of the normal fee. The debt has not been resolved 
and is not part of the consolidation of her student loans. (Tr. 47-49) 
 
The delinquent debt for $654 at SOR 1.h is for her son’s cell phone. He incurred 
a large bill one month and Applicant notified the phone company to block her son’s 
access to texting and calling. The phone company did not block his phone and a large 
debt was incurred the next month. She disputed the debt with the phone company, but it 
has not been resolved. (Tr. 49-51) 
 
The delinquent debt for $5,151 at SOR 1.i is for a 2007 car repossession. The 
car was a used car she purchased for approximately $12,000. She had the car for about 
 
 
 
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a year. Her commute to work was expensive and she had child care expenses. She 
could not afford the car so it was repossessed. She remembers receiving a statement 
about the car but does not remember the amount owed. The debt has not been 
resolved. (Tr. 52-53) 
 
The delinquent debts at SOR 1.j to 1.n are medical debts from Applicant’s 2010 
thyroid surgery. Applicant’s 2010 state tax return was applied to the debts at SOR 1.l 
and 1.m. The debt at SOR 1.l has been paid in full and the debt at SOR 1.m reduced to 
$254. Applicant’s 2011 state tax refund was applied to the debt at SOR 1.j. The debt is 
paid in full. The other debts have not been resolved. She does not have information on 
the debt at SOR 1.n. (Tr. 51-55; App. Ex. B, Tax Receipt, dated February 7, 2011; App. 
Ex. C, Hospital Statement, dated September 27, 2010; App. Ex. I, Tax Refund, dated 
February 3, 2012) 
 
Applicant’s student loans at SOR 1.o, 1.u, 1.w, and 1.x have been consolidated 
and are in a rehabilitation program. Applicant paid the first installment on the 
rehabilitation program and subsequent payments will be automatically deducted from 
her account. (Tr. 19-20; App. Ex. A, Rehabilitation Documents and Bank Transaction, 
dated July 27, 2012; App. Ex. J, Bank Transaction, dated August 21, 2012) 
 
The delinquent debt for $423 at SOR 1.p is from an apartment lease dispute. 
There was a violent incident in the apartment complex where Applicant lived in 2011. 
She notified the landlord that she would be moving at the end of the one year lease. 
She had an unexpected major medical problem requiring an operation and 
recuperation. She tried to extend the lease but the apartment was rented. When 
Applicant moved, the landlord claimed there was damage needing repair. Applicant 
claimed the apartment was in excellent condition and disputed the need for repairs. She 
has pictures of the condition of the apartment when she left. The dispute has not been 
resolved. (Tr. 55-57) 
 
The delinquent debt for $1,109 at SOR 1.q is for a credit card Applicant acquired 
in 2007. She was trying to rebuild her credit but was laid off and could not continue to 
pay the bill. The debt has not been resolved.  (Tr. 57-58) 
 
The delinquent debt for $69 at SOR 1.r is for cable television service. Applicant 
had service with the same company in 1999 to 2003, in 2005, and again in 2008. She 
did not like the service in 2008 and canceled the contract. However, the company 
debited her bank account for equipment charges. She disputed this at the time. She has 
not been in contact with the company recently, and the debt is not resolved. (Tr. 58-59)  
 
The delinquent debt for $152 at SOR 1.s is a medical debt. Applicant has 
researched the debt but was unable to learn the origin of the debt. It has not been 
resolved. (Tr. 59) 
 
 
 
 
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The delinquent debts at SOR 1.t ($439), 1.gg ($440), and 1.jj ($440) are the 
same debt for computer service equipment from a phone company. Applicant inquired 
from the phone company if computer service was available. She was told that it was not 
available but the phone company sent the equipment anyway. She never opened the 
box and did not know it contained equipment. When she moved and requested service 
at her new address, she was advised of the bill for the equipment. She found the box 
unopened and offered to return it to the phone company. The phone company would not 
accept it. She disputes the debt and it has not been resolved. (Tr. 59-61) 
 
The delinquent debt for $245 at SOR 1.v is for cable service at one of her former 
residences. The debt has not been resolved. (Tr. 61) 
 
The delinquent debt for $1,322 at 1.y is for apartment rent before Applicant 
moved to her present location in February 2010. Applicant was three months into a one 
year lease when she admits making a business decision to break the lease to move for 
a better job. She provided thirty day notice of her intent to move. She is in negotiation 
with the leasing agent to settle the debt for half of the amount requested. (Tr. 61-64) 
 
The delinquent debt for $145 at SOR 1.z is for television service Applicant and 
her first husband had in 2002. The debt has not been resolved. (Tr. 64) 
 
The delinquent debts at SOR 1.aa ($149) and 1.ff ($149) are the same debt. It 
was a joint bank account Applicant had with her second husband. She was unaware of 
the debt because it was necessary for her to leave her husband. She believes the debt 
is her former husband’s debt and she does not know if it has been resolved. (Tr. 64-65) 
 
The delinquent debts at SOR 1.bb ($65), 1.cc ($50), 1.dd ($207), and i.ee ($11), 
were incurred over 16 years ago. Applicant is unaware of these debts. Some of the 
medical offices no longer exist. She does not know if they have been resolved. (Tr. 65-
66) 
 
The delinquent debt for $284 at SOR 1.hh is for a hospital emergency room visit 
over 16 years ago caused by a self-inflicted injury to her son. The debt has not been 
resolved. (Tr. 66-67)  
 
The delinquent debts at SOR 1.ii ($106), 1.kk ($291), 1.ll ($82), 1.pp ($154), 1.qq 
($35), 1.rr ($291), and 1.ss ($291) are other old medical debts. The debts at 1.rr and 
1.ss are the same debt. Applicant is not aware of the debts and does not know if it has 
been resolved. (Tr. 67, 70) 
 
The delinquent debt for $154 at SOR 1.mm is a medical debt from the medical 
facility that initially treated her son’s mental issues. Applicant had health insurance at 
the time but had to pay all other charges so her son would continue to be treated. Since 
the treatment of her son was her top priority, she was sure all of the bills were paid. She 
disputed this debt, but it has not been resolved. (Tr. 67-68) 
 
 
 
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The delinquent debt for $4,762 at SOR 1.nn is from a chiropractor who treated 
Applicant after an accident in 2001 that she claims was not her fault. She disputed the 
case and it went to litigation. She lost the litigation but she has not paid the claim and 
has not been contacted again by the chiropractor. (Tr. 68-70) 
 
The delinquent debt for $154 at SOR 1.tt is for emergency room treatment of her 
son. She believes it is a co-payment, but it has not been resolved. (Tr. 71) 
 
Applicant is current with her federal and state taxes. She applied recent tax 
refunds to debt relief, and to supplement her income since her co-habitant was not 
working. She has not had formal debt counseling. However, she has kept extensive and 
accurate financial records and was able to provide the spreadsheet on the status of her 
SOR debts. She also paid some debts not included in the SOR. (Tr. 72-73; app. Ex. L, 
Account Statement, dated August 2, 2012; App. Ex. M, Account Statement, dated 
October 11, 2012; App. Ex. N, Billing Statement, dated July 23, 2012) 
 
Applicant’s immediate supervisor wrote that she has been a valuable addition to 
their company. He has known her for over two years, and she works directly for him. 
She is one of the best people he has working for him. She is highly intelligent and very 
responsible. (App. Ex. E, Letter, undated) Applicant performance evaluation shows that 
her work is rated as outstanding and above expectations. (App. Ex. F, Performance 
Evaluation dated April 2, 2009) 
 
Policies 
 
When evaluating an applicant’s suitability for a security clearance, the 
administrative judge must consider the adjudicative guidelines. In addition to brief 
introductory explanations for each guideline, the adjudicative guidelines list potentially 
disqualifying conditions and mitigating conditions, which must be considered in 
evaluating an applicant’s eligibility for access to classified information. 
 
These guidelines are not inflexible rules of law. Instead, recognizing the 
complexities of human behavior, these guidelines are applied in conjunction with the 
factors listed in the adjudicative process. The administrative judge’s overarching 
adjudicative goal is a fair, impartial, and commonsense decision. According to AG ¶ 
2(c), the entire process is a conscientious scrutiny of a number of variables known as 
the “whole-person concept.” The administrative judge must consider all available, 
reliable information about the person, past and present, favorable and unfavorable, in 
making a decision. 
 
The protection of the national security is the paramount consideration. AG ¶ 2(b) 
requires that “[a]ny doubt concerning personnel being considered for access to 
classified information will be resolved in favor of national security.” In reaching this 
decision, I have drawn only those conclusions that are reasonable, logical, and based 
on the evidence contained in the record.  
 
 
 
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Under Directive ¶ E3.1.14, the Government must present evidence to establish 
controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, the applicant is 
responsible for presenting “witnesses and other evidence to rebut, explain, extenuate, 
or mitigate facts admitted by applicant or proven by Department Counsel. . . . .” The 
applicant has the ultimate burden of persuasion in seeking 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 that the applicant may deliberately or inadvertently fail to 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. 
 
Analysis 
 
Financial Considerations 
 
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. 
(AG ¶ 18) Similarly, an individual who is financially irresponsible may also be 
irresponsible, unconcerned, or careless in his or her obligations to protect classified 
information. Behaving responsibly or irresponsibly in one aspect of life provides an 
indication of how a person may behave in other aspects of life.  
 
A person’s relationship with his or her creditors is a private matter until evidence 
is uncovered demonstrating an inability or unwillingness to repay debts under agreed 
terms. Absent evidence of strong extenuating or mitigating circumstances, an applicant 
with a history of serious or recurring financial difficulties exhibits a risk inconsistent with 
the holding of a security clearance. An applicant is not required to be debt free, but is 
required to manage her finances in such a way as to meet her financial obligations. 
Applicant's delinquent debts established by credit reports and Applicant’s admissions 
raise Financial Considerations Disqualifying Conditions AG ¶ 19(a) (inability or 
unwillingness to satisfy debts); and AG ¶ 19(c) (a history of not meeting financial 
obligations). The evidence indicates an inability and not an unwillingness to satisfy debt. 
Applicant incurred financial problems when she was laid off a number of times and was 
unemployed for over two years in a four year period. She also had extensive medical 
debt for treatment of herself and her son. She always sought better employment after 
she was laid off.  
 
 
 
 
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I considered Financial Considerations Mitigating Conditions 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) and AG ¶ 20(b) (the conditions 
that resulted in the financial problems 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). 
These mitigating conditions apply. Most of her debts are medical debts over 16 years 
old from extensive medical treatment for either her son or herself. She also was laid off 
a number of times and was unemployed for two years in a four year period. The debts 
are not for extravagant purchases but are medical debts and debts caused by her 
efforts to gain better employment opportunities. The debts happened long ago and were 
largely caused by conditions beyond her control. She acted responsibly under the 
circumstances. She kept detailed financial records, contacted the creditors that she was 
aware of, and has paid the debts she could within her financial resources. She is 
negotiating settlement agreements on other debts. She has steady and good 
employment, and is not likely to incur additional debts. She has been able to save a little 
money, and her present finances are under control. Applicant established that she acted 
responsibly towards her debts under the circumstances. 
 
I considered AG ¶ 20(d) (the individual has initiated a good-faith effort to repay 
the overdue creditors or otherwise resolve debts). For AG ¶ 20(d) to apply, there must 
be an “ability” to repay the debts, the “desire” to repay, and “evidence” of a good-faith 
effort to repay. Good faith means acting in a way that shows reasonableness, prudence, 
honesty, and adherence to duty and obligation. A systematic method of handling debts 
is needed. Applicant must establish a "meaningful track record" of debt payment. A 
"meaningful track record" of debt payment can be established by evidence of actual 
debt payments or periodic payments to reduce debts. Applicant is not required to 
establish that she paid each and every debt listed. All that is required is that Applicant 
has an established plan to resolve her financial problems, and shows she has taken 
significant actions to implement that plan. 
 
Using her extensive financial records, Applicant was able to establish that five of 
the SOR debts are duplicates. She established that she paid four of the debts and is 
paying two others. She is disputing ten debts. She is negotiating settlement agreements 
on two debts. She knows of and admits six of the non-medical debts but has not had the 
financial resources to pay or settle them. The remaining debts are old medical debts 
that she has not had the resources to settle and pay. Some of the creditors are also 
unknown.  
 
I also considered AG ¶ 20(e) (the individual has a reasonable basis to dispute 
the legitimacy of the past-due debt which is the cause of the problem and provides 
documented proof to substantiate the basis of the dispute or provides evidence of 
actions to resolve the issue). Applicant is disputing ten of the debts. She has a 
 
 
 
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legitimate basis for the disputes based on the extensive financial records she maintains. 
The debts are old and have not been resolved.  
 
I considered AG ¶ 20(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). Applicant admits that she has not sought or received financial 
counseling. However, she kept extensive and detailed financial records. The 
management of her finances, the records she kept, and her action to address her 
delinquent debts establish that her financial problems are being resolved and are under 
control. Her efforts to learn about and resolve her debts are significant and credible 
information and show a desire to resolve debt. Her payment of debts establishes a 
meaningful track record of debt payment. These efforts show a reasonable and prudent 
adherence to financial obligations, and establish a good-faith effort to resolve and pay 
debts. Her past delinquent debts do not reflect adversely on her trustworthiness, 
honesty, and good judgment. Based on all of the financial information provided by 
Applicant, I conclude that she mitigated security concerns based on financial 
considerations  
 
Whole-Person Analysis 
 
Under the whole-person concept, the administrative judge must evaluate an 
applicant’s security eligibility by considering the totality of the applicant’s conduct and all 
relevant circumstances. An 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 a security clearance 
must be an overall commonsense judgment based upon careful consideration of the 
guidelines and the whole-person concept.  
 
I considered the potentially disqualifying and mitigating conditions in light of all 
the facts and circumstances surrounding this case. I considered that Applicant is highly 
regarded by her employer and is an excellent worker. Applicant has had a difficult time 
financially in her life. Many delinquent debts were caused by lay-offs and medical bills 
that were beyond her control. Applicant kept meticulous financial records and has a firm 
grasp on the status of her debts. She paid, is paying, or is disputing most of her debts. 
When she has financial resources, she takes action to pay past-due obligations. 
 
 
 
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Applicant has shown her good-faith efforts to pay or resolve her delinquent debts. Her 
finances are under control. Her actions in regard to her past financial obligations 
indicate that she will be concerned, responsible, and careful regarding classified 
information. 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 security concerns arising from financial considerations. 
She is granted access to classified information.  
 
Formal Findings 
 
Formal findings for or against Applicant on the allegations set forth in the SOR, 
as required by section E3.1.25 of Enclosure 3 of the Directive, are: 
 
 Paragraph 1, Guideline F:   FOR APPLICANT 
 
 Subparagraphs 1.a – 1.tt:   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. 
 
 
 
_________________ 
THOMAS M. CREAN 
Administrative Judge