Consisting of the transcript (Tr.), Government exhibits (GE) 1-4, and Applicant exhibits (AE) A-B. 1
DOHA acted under Executive Order 10865, Safeguarding Classified Information within Industry (February2
20, 1960), as amended; Department of Defense (DoD) Directive 5220.6, Defense Industrial Personnel Security
Clearance Review Program  (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG)
effective within the DoD on 1 September 2006. 
1
                                                                               
                           DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
XXXXXXX, Xxxxxxxx Xxxxx )       ISCR Case No. 11-03217
)
Applicant for Security Clearance )
Appearances
For Government: Raashid S. Williams, Esquire, Department Counsel
For Applicant: Pro se
______________
Decision
______________
METZ, John Grattan, Jr., Administrative Judge:
Based on the record in this case,  I grant Applicant’s clearance.1
On 20 April 2012, the Defense Office of Hearings and Appeals (DOHA) issued a
Statement of Reasons (SOR) to Applicant detailing security concerns under Guideline
F, Financial Considerations.  Applicant timely answered the SOR, requesting a hearing.2
DOHA assigned the case to me 9 August 2012, and I convened a hearing 11
September 2012. DOHA received the transcript (Tr.) 17 September 2012.
 
2
Findings of Fact
Applicant denied the SOR allegations. She is a 32-year-old office manager
employed by a defense contractor since April 2010. She will also be the company
facility security officer (FSO) if she gets her clearance. She has not previously held a
clearance.
The SOR alleges, and Government exhibits confirm, eight delinquent debts
totaling over $15,000. Nearly $12,000 of the delinquent debt is for an education loan. 
According to her Answer and supporting documents, Applicant entered into
repayment plans on SOR debts 1.a ($1,388), 1.b ($664), and 1.c ($11,558). She paid
SOR debt 1.d ($194) in April 2012. Applicant paid SOR debt 1.e ($534) in May 2006.
The listed creditor for SOR debt 1.f ($677) could find no record of the account, and it
has been removed from her credit report. She paid SOR debt 1.g ($120) in April 2012.
She paid SOR debt 1.h ($305) with two payments made in May and July 2012 (Answer,
AE 1).
Applicant’s financial problems were largely the result of her financial naivete and
her decision to actively participate in the political process after graduating from college
in December 2003. From July 2004 to November 2004, she worked as a youth
campaign director for a state political party. From July 2006 to November 2006, she
worked as the finance director for a congressional campaign. From August 2007 to
August 2008, she worked as a regional field director for a presidential campaign.
 Before and after campaigns, Applicant worked at a variety of jobs that can best
be described as temporary, lower-paying jobs, even if she was employed full time at
them. The job she obtained in April 2010 is the first truly permanent employment that
she has had since graduating college.
In addition to the lower-paying jobs she had between campaigns, Applicant’s
campaign jobs did not pay particularly well, and her finances were further complicated
by the campaign financing used by her employers. She traveled extensively and was
responsible for setting up local campaign offices and getting her own temporary
housing. Although these expenses were subject to reimbursement, payments were not
made until a given event passed—e.g. primary election. For example, in the presidential
campaign, she began working in August 2007, but the state presidential primary was
not until February 2008. In addition, reimbursements were also not always timely made.
Although Applicant fronted the money to the campaigns, by the time she was
reimbursed she would typically have what she considered more pressing financial
matters, and did not always use the reimbursements to pay those debts.
In 2007, Applicant began to realize her impending financial disaster, but it was
not until 2009 that she really began to focus on addressing her financial issues. She
started by moving her finances to a strictly cash basis. Once she began her current job
in April 2010, she was better positioned to address her delinquent debts. When she
See, Department of the Navy v. Egan, 484 U.S. 518 (1988).3
3
completed her clearance application in May 2010 (GE 1), she disclosed five of the eight
debts alleged in the SOR, and one debt not alleged in the SOR. In addition to the debts
alleged in the SOR, Applicant’s June 2010 credit report (GE 2) showed three paid
collection accounts and a past-due account that she brought current by the time the
SOR was issued. Her March 2012 response to DOHA interrogatories showed that she
had already begun repayment on her education loan and provided a detailed schedule
of planned debt payments for each of her bi-weekly paychecks from March 2013 to
January 2013, when she projected to have paid all her debts except for the education
loan. However, as she claimed she would do in her response to DOHA interrogatories if
her finances permitted, she was able to accelerate her payments to pay all her debts
except the education loan before the hearing.
Applicant has not received any formal financial counseling, but has read two self-
help books by a nationally-recognized financial advisor. She established a detailed
budget and is current on her day-to-day living expenses. The vice-president and FSO of
her company finds her honest and trustworthy, and recommends her for her clearance.
Policies
The adjudicative guidelines (AG) list factors for evaluating a person’s suitability
for access to classified information. Administrative judges must assess disqualifying and
mitigating conditions under each issue fairly raised by the facts and situation presented.
Each decision must also reflect a fair, impartial, and commonsense consideration of the
factors listed in AG ¶ 2(a). Any one disqualifying or mitigating condition is not, by itself,
conclusive. However, specific adjudicative guidelines should be followed where a case
can be measured against them, as they represent policy guidance governing access to
classified information. Considering the SOR allegations and the evidence as a whole,
the relevant adjudicative guideline is Guideline F (Financial Considerations).
Security clearance decisions resolve whether it is clearly consistent with the
national interest to grant or continue an applicant’s security clearance. The Government
must prove, by substantial evidence, controverted facts alleged in the SOR. If it does,
the burden shifts to applicant to refute, extenuate, or mitigate the Government’s case.
Because no one has a right to a security clearance, the applicant bears a heavy burden
of persuasion.
Persons with access to classified information enter into a fiduciary relationship
with the Government based on trust and confidence. Therefore, the Government has a
compelling interest in ensuring each applicant possesses the requisite judgement,
reliability, and trustworthiness of those who must protect national interests as their own.
The “clearly consistent with the national interest” standard compels resolution of any
reasonable doubt about an applicant’s suitability for access in favor of the government.3
¶ 19(a) inability or unwillingness to satisfy debts; (c) a history of not meeting financial obligations;4
¶ 20(a) the behavior happened so long ago, was so infrequent, or occurred under such circumstances that5
it is  unlikely to recur . . . 
¶ 20(b) the conditions that resulted in the financial problem were largely beyond the person’s control . . . and6
the individual acted responsibly under the circumstances;
¶ 20(c) the person has received or is receiving counseling for the problem and there are clear indications that7
the problem is being resolved or is under control;
¶ 20(d) the individual initiated a good-faith effort to repay overdue creditors or otherwise resolve debts.8
ISCR Case No. 07-06482 (App. Bd. 21 May 2008).9
4
Analysis
The Government established a case for disqualification under Guideline F, but
Applicant mitigated the security concerns. Applicant experienced financial problems
because of her financial inexperience and employment choices she made after college.
Consequently, she neglected her financial responsibilities.4
The mitigating factors for financial considerations have mixed applicability. While
her financial difficulties are recent and numerous, the circumstances under which they
occurred were unique and unlikely to recur.  Similarly, her financial problems were not5
due to circumstances beyond her control. They were caused by Applicant’s decision to
work on political campaigns, and her failure to use her reimbursements to satisfy the
debts she had incurred on the campaigns. However, she was not living an extravagant
lifestyle, and her desire to participate in political campaigns is a different motivation for
neglecting her finances than is typical in a financial case. Further, once Applicant
decided to focus on her finances, she acted quickly and responsibly in addressing her
debts under the circumstances.  While she has not sought credit counseling, she has6
improved her knowledge of financial matters on her own, operates from a detailed
budget, and has clearly resolved all the debts, except for the education loan that she is
making regular payments on.  Finally, she started addressing her debts right after she7
obtained her first permanent job, before she received the DOHA interrogatories and the
SOR. While those actions were pending, she continued to address her debts, and in the
circumstances of this case, that action constitutes a good-faith effort to satisfy her
debts.  The record does not suggest that Applicant’s financial problems will recur. The8
Appeal Board has stated that an Applicant need not have paid every debt alleged in the
SOR, need not pay the SOR debts first, and need not be paying on all debts
simultaneously. Applicant need only establish that there is a credible and realistic plan
to resolve the financial problems, accompanied by significant actions to implement the
plan.  Applicant has such a plan and has taken such actions. Accordingly, I conclude9
Guideline F for Applicant.
5
Formal Findings
Paragraph 1. Guideline F: FOR APPLICANT
Subparagraphs a-h: For Applicant
Conclusion
Under the circumstances presented by the record in this case, it is clearly
consistent with the national interest to grant or continue a security clearance for
Applicant. Clearance granted.   
                                              
                                             
JOHN GRATTAN METZ, JR
Administrative Judge