KEYWORD: Guideline F
DIGEST: Applicant had not provided any information about her income, expenses, or her
husband’s circumstances.  The available information was not sufficient to mitigate the concerns
arising from Applicant’s delinquent debts.  Adverse decision affirmed.
CASENO: 14-00210.a1
DATE: 01/07/2015
DATE: January 7, 2015
In Re:
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Applicant for Security Clearance
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ISCR Case No. 14-00210
APPEAL BOARD DECISION
APPEARANCES
FOR GOVERNMENT
James B. Norman, Esq., Chief Department Counsel
FOR APPLICANT
Pro se
The Department of Defense (DoD) declined to grant Applicant a security clearance.  On
March 19, 2014, DoD issued a statement of reasons (SOR) advising Applicant of the basis for that
decision–security concerns raised under Guideline F (Financial Considerations) of Department of
Defense Directive 5220.6 (Jan. 2, 1992, as amended) (Directive).  Applicant requested a decision
on the written record.  On October 17, 2014, after considering the record, Defense Office of
Hearings and Appeals (DOHA) Administrative Judge Juan J. Rivera denied Applicant’s request for
a security clearance.  Applicant appealed pursuant to Directive ¶¶  E3.1.28 and E3.1.30.
Applicant raised the following issue on appeal: whether the Judge’s adverse decision ran
contrary to the weight of the record evidence and, therefore, was arbitrary, capricious, or contrary
to law.  Consistent with the following, we affirm.
The Judge’s Findings of Fact
Applicant is employed by a Government contractor.  A high school graduate, she and her
husband have two adult offspring, one of whom is serving in the U.S. military.  Applicant
experienced a period of unemployment from the middle of 2012 until the middle of 2013, at which
point she was hired by her current employer.
Applicant’s SOR alleges four debts that total over $17,000.  ¶ 1(a) refers to a judgment
against Applicant in the amount of $6,423.  She claims that ¶ (b), a collection account in the amount
of $9,553, is a repetition of this debt, which arose from a delinquent credit card account.  She
advised that the account became delinquent in 2006, during a time in which her husband was
unemployed due to illness.  In her security clearance application (SCA), Applicant claimed that she
was negotiating a settlement with the creditor of 1(b).  She did not corroborate any contact with this
creditor.  
In her answer to the SOR, Applicant stated that 1(b) no longer appeared on her credit report
but that the debt alleged in 1(a) did appear on it.  She stated her belief that these two allegations refer
to one underlying debt and that she had filed a dispute with the credit bureaus.  She asked that 1(a)
be removed from her credit report.
The Judge found that Applicant presented insufficient evidence that the two allegations
address the same debt.  Neither did she present documentary evidence showing the outcome of her
dispute with the credit bureaus.  Applicant has not presented documentary evidence to corroborate
any payments or other efforts to resolve these debts.  
Applicant’s November 2013 credit report shows 14 accounts, including the four delinquent
ones alleged in the SOR.  The Judge stated that, without more evidence, it is not possible to
determine if Applicant is financially overextended or living beyond her means.
Applicant demonstrated resolution of the debts alleged at ¶¶ 1(c) and (d).  She paid the
former and successfully disputed the latter.  However, she provided little information about her
current earnings and financial position.  She provided no information about her monthly income and
expenses, any income generated by her husband, or whether her income is sufficient to cover her
ordinary expenses.  She has provided no information concerning financial counseling or whether she
has a budget.
The Judge’s Analysis
1See Directive, Enclosure 2 ¶ 19(a): “inability or unwillingness to satisfy debts;” and ¶ 19(c): “a history of not
meeting financial obligations[.]”  
2Directive, Enclosure 2 ¶ 20(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[.]”
The Judge concluded that Applicant’s financial circumstances raised concerns under
Guideline F.1  He resolved SOR ¶¶ 1(c) and (d) in Applicant’s favor.  However, he concluded that
she had not met her burden of persuasion regarding the other two allegations.  Although he noted
evidence that Applicant and her husband had experienced unemployment, which were circumstances
beyond their control, he concluded that Applicant had not demonstrated responsible action in regard
to the two debts at issue.2  He noted that she had not presented evidence to show payments or contact
with creditors, except for disputing them on the ground that she believes they are not collectible.
He also stated that she had provided no information about her income, expenses, or her husband’s
circumstances.  He concluded that the available information is not sufficient to mitigate the concerns
arising from Applicant’s delinquent debts.  
In the whole-person analysis, the Judge cited to evidence that Applicant “seems to be on the
path to establish financial responsibility.”  Decision at 6.  However, he reiterated his conclusion that
she had not presented enough evidence to show responsible action regarding the two large
delinquent debts alleged in SOR ¶¶ (a) and (b).  
Discussion
Applicant argues that the Judge did not properly interpret the evidence.  She states that the
record shows that her remaining debts have been paid rather than merely disputed.  To the extent
that she is arguing the Judge’s findings are erroneous, we conclude that Applicant’s admission to
the SOR, her statements in the SCA, and her credit report support the Judge’s findings.  The findings
are based upon substantial evidence or constitute reasonable inferences that could be drawn from
the evidence.  See, e.g., ISCR Case No. 12-03420 at 3 (App. Bd. Jul. 25, 2014).  Given the record
that was before him, the Judge’s findings and conclusions regarding the absence of corroboration
are sustainable.  
To the extent that Applicant is arguing that the Judge erred in concluding that the record
raised security concerns, we note the evidence described above:  Applicant admitted the debt alleged
in SOR ¶ 1 (a), both 1(a) and (b) were contained in her credit report, and she discussed her financial
problems in her SCA.  A credit report itself is often sufficient to meet the Government’s burden of
producing evidence of security concern.  See, e.g., ISCR Case No. 13-00987 at 3 (App. Bd. Aug.
14, 2014).  Insofar as the Directive presumes a nexus between admitted or proven conduct and an
applicant’s security worthiness, the Judge did not err in his conclusion that the evidence raised
concerns under Guideline F.  See, e.g., ISCR Case No. 14-00114 at 4 (App. Bd. Sep. 30, 2014).  
We have examined the Judge’s decision in light of the record as a whole.  His conclusions
about the paucity of mitigating evidence are consistent with the record that was before him.  An
applicant bears the burden of persuasion to mitigate the concerns raised by his or her conduct or
circumstances.  Directive ¶ E3.1.15.  In this case, the Judge’s conclusion that Applicant had not met
that burden is supportable.  His decision did not contravene the weight of the evidence.  
The Judge examined the relevant data and articulated a satisfactory explanation for the
decision.  The decision is sustainable on this record.  “The general standard is that a clearance may
be granted only when ‘clearly consistent with the interests of the national security.’”  Department
of the Navy v. Egan, 484 U.S. 518, 528 (1988).  See also Directive, Enclosure 2 ¶ 2(b):  “Any doubt
concerning personnel being considered for access to classified information will be resolved in favor
of the national security.”
Order
The Decision is AFFIRMED.  
Signed: Michael Ra’anan              
Michael Ra’anan
Administrative Judge
Chairperson, Appeal Board
Signed: William S. Fields             
William S. Fields
Administrative Judge
Member, Appeal Board
Signed: James E. Moody                
James E. Moody
Administrative Judge
Member, Appeal Board