1
 
                                                             
                           DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
)       ISCR Case No. 14-03765
)
Applicant for Security Clearance )
Appearances
For Government: Jeff A. Nagel, Esquire, Department Counsel
For Applicant: Pro se  
______________
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 completed and certified an Electronic Questionnaire for Investigations
Processing (e-QIP) on October 31, 2013. The Department of Defense (DOD) issued
Applicant a Statement of Reasons (SOR) on December 2, 2014, 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; DOD 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).
AE D - AE M.2
2
Applicant received the SOR, and he answered it on December 27, 2015.
Applicant requested a hearing before an administrative judge with the Defense Office of
Hearings and Appeals (DOHA). Department Counsel was prepared to proceed on
February 10, 2015, and I received the case assignment on March 2, 2015. DOHA
issued a Notice of Hearing on April 17, 2015, and I convened the hearing as scheduled
on May 13, 2015. Through a joint stipulation of admissibility, the Government offered
exhibits (GE) marked as GE 1 through GE 4. The Government also offered GE 5 at the
hearing, which was received and admitted into evidence without objection. Applicant
testified. He submitted exhibits (AE) marked as AE A through AE N, which were
received and admitted into evidence without objection. DOHA received the hearing
transcript (Tr.) on May 21, 2015. I held the record open until June 13, 2015, for
Applicant to submit additional matters. Applicant timely requested additional time to
submit his documents. In an Order dated June 11, 2015, Applicant was given until July
13, 2015 to submit additional documentation. He timely submitted AE O - AE W, which
were received and admitted without objection. The record closed on July 13, 2015.
Findings of Fact
In his Answer to the SOR, Applicant admitted the factual allegations in ¶¶ 1.a -
1.k and 1.m - 1.t of the SOR. His admissions are incorporated herein as findings of fact.
He denied the factual allegation in ¶ 1.l of the SOR.  He also provided additional1
information to support his request for eligibility for a security clearance. After a complete
and thorough review of the evidence of record, I make the following findings of fact.  
Applicant, who is 50 years old, works as an operations officer for a DOD
contractor. He began working for his current employer in February 2013. Applicant
submitted one commendation letter and nine letters of recommendation for a security
clearance. The owner of his company, who is also a vice president and the chief
technical officer of the company, has known Applicant for ten years and describes him
as hardworking, serious, and knowledgeable about his work. He has never witnessed
Applicant abuse his position or authority, and he notes that Applicant takes his
responsibility to protect sensitive information and technology seriously. He trusts
Applicant with the most sensitive information and technology of the company and the
government. Several other colleagues similarly describe him. Friends, his pastor, and
coworkers have great respect for Applicant and trust him. All recommend him for a
security clearance based on their trust and confidence in Applicant. Some know about
his financial problems arising from his divorce.2
GE 1; AE B; AE E - AE M; Tr. 25. 3
Response to SOR; Tr. 25-29.4
Applicant indicated that he had documentation to prove that his former wife took $57,000 from his accounts.5
Other documentation tends to show she may have taken up to $102,000 from him. Tr.42.
Response to SOR; AE B; AE C; Tr. 30-35, 64.6
3
Applicant graduated from high school in 1983. He married in 1994 and divorced
in 2009. He has a 20-year-old daughter, who lives with him and attends college. The
record lacks any evidence that Applicant has been disciplined at work for any reason or
that he mishandled classified or proprietary information. Likewise, the record evidence
does not indicate that he has been involved with drugs or been arrested.3
Applicant’s financial problems began when he and his wife separated in 2008. He
describes his divorce as extremely difficult, in part due to his former wife’s emotional
and physical abuse of their daughter and him. Under the terms of the divorce
settlement, Applicant and his former wife shared legal joint custody of their daughter,
while Applicant maintained full-time physical custody of his daughter. Since he and his
former wife shared legal custody of their daughter, the court ordered him to pay his
former wife $1,000 a month in child support until their daughter graduated from high
school, which occurred in June 2014. The court also ordered Applicant to pay $1,500 a
month in alimony to his former wife until December 2014. Besides these payments and
at Applicant’s request, the domestic relations master recommended counseling for
Applicant’s daughter and wife, and he paid for the counseling. For the first several years
of his divorce, Applicant paid at least $3,000 a month for alimony, child support and
counseling.  4
In addition to custody and support issues, Applicant’s divorce degree specifically
addressed other financial matters. Because he traveled in dangerous areas at times for
work, Applicant long ago gave his wife a power of attorney. Before their divorce
finalized, his wife used the power of attorney to take funds from various accounts,
including his daughter’s education fund. Specifically related to the SOR debts, in July
2008, his former wife took $12,653 from his 401(k) account and $29,642 from his
annuity.  The withdrawals were taken prematurely, creating a tax liability. Applicant5
requested to include in the divorce decree specific language about payment of these
taxes. His wife and the court agreed. Under the terms of his divorce decree, Applicant’s
wife is to pay the taxes assessed for the early withdrawal of this money or to indemnify
Applicant for any taxes he paid related to this withdrawal. Applicant assumed
responsibility for all marital debts.6
The SOR identified 20 purportedly continuing delinquencies as reflected by credit
reports from 2008, 2013, and 2015, totaling approximately $237,028.  Some accounts
have been transferred, reassigned, or sold to other creditors or collection agents. Other
accounts are referenced repeatedly in both credit reports, in many instances duplicating
other accounts listed, either under the same creditor or collection agency name or under
This amount includes penalties and interest and is most likely based on more than the $42,000 previously7
listed as taken from his 401(k). Response to SOR; AE B.
Response to SOR; AE B; Tr. 33-35, 42-43.8
Applicant understood that by filing the levy, the IRS could take up to 90% of his income.9
AE P; Tr. 36-40.10
The original lender identified on the mortgage, now out of business, was a company developed and owned11
by the Lender 1 creditor listed in the SOR.
4
a different creditor or collection agency name. Some accounts are identified by
complete account numbers, while others are identified by partial account numbers, in
some instances eliminating the last four digits and in others eliminating other digits.
Applicant timely files his federal and state income tax returns each year.
Following the withdrawal of funds from his retirement accounts by his former wife, the
Internal Revenue Service (IRS) received notification of the withdrawal. In 2010, the IRS
audited Applicant’s 2008 tax return. The IRS determined that Applicant owed taxes on
the money withdrawn by his former wife as his social security number was on the
account. The IRS demanded payment of almost $30,000 from him despite the terms of
his divorce decree.  Applicant tried to enforce these terms against his wife, but she still7
refused to pay the taxes owed. To date, Applicant’s former wife has neither paid nor
indemnified him for these taxes.8
Applicant contacted the IRS to discuss payment of the tax debt. After this
contact, the IRS filed a levy, not garnishment, against his salary for $30,239. The IRS
took $500 from this paycheck.  In November 2011, the IRS filed a tax lien on Applicant’s9
home and against him in the amount of $27,843. (SOR allegation 1.a) Applicant
retained his divorce lawyer to help him with the IRS matter. The IRS released the levy
on October 3, 2012. With the assistance of counsel, he and the IRS reached an
agreement in December 2012 that he would pay $500 a month on his tax debt.
Applicant made payments to the IRS; all federal tax refunds were applied to the balance
owed; and he directed his state tax refund for the years 2013 and 2014 be applied to his
federal tax debt. With his tax refunds for the 2014 tax year, he fully paid the remaining
$14,000 balance on his federal tax debt. The IRS release its lien on May 13, 2015.   10
Applicant grew up in the east. He moved west as a young man. Around 2003, he
moved his family east to State A. They purchased a home in State A, which was some
400 to 500 miles from Applicant’s place of work. He commuted weekly to his job in State
B. Eventually, Applicant found this arrangement unsatisfactory, sold his house in State
A, and moved his family to State C, which was closer to his job in State B. He
purchased a house in State C. When he and his wife separated, he lived in State C and
worked in State B. SOR allegation 1.l ($142,500) relates to the mortgage on Applicant’s
house in State A. Lender 1  held the original mortgage, but later sold the mortgage to11
Lender 2. Applicant provided a copy of the settlement papers and of the Satisfaction of
Mortgage line filed on August 25, 2009 by Lender 2. Applicant satisfied any
Attachment to Response to SOR; AE R; Tr. 44-46, 62, 72-77.12
AE N; Tr. 49-54, 68, 81-83.13
Response to SOR; AE O; AE R; AE S; Tr. 52-53, 57-58.14
5
indebtedness to Lender 1 when this company sold his mortgage to Lender 2. Applicant
sold the house used as collateral on the mortgage, and the settlement papers reflect
that he paid the balance of his loan. The house he purchased in State C sold through
foreclosure, and the creditor forgave the home equity loan of $115,000 and issued a
1099-C. Applicant claimed this money as income for the tax year 2012.12
After completing his alimony and child support payments, Applicant started
contacting the creditors listed in the SOR.  He was unable to reach some creditors, and
others wanted lump sum payments to resolve the debts owed. He attempted to set up
small monthly payments with all the SOR creditors, but was unable to do so. After
discussions and review of his past-due debts, Applicant signed an agreement with a
debt resolution company on the day of his hearing. Applicant will pay $616 a month to
this company for 46 months. The company will deduct its fee and use the remaining
money to resolve 10 of the debts listed on the SOR. The company declined to accept
for settlement the debts in SOR allegations 1.f ($122), 1.k ($132), 1.n ($475), and 1.p
($52). The debts in SOR allegations 1.h ($7,686), 1.i ($9,070) and 1.j ($8,970) are owed
to the same creditor. Applicant advised that the debt resolution company told him that
after talking with the creditor, he only owed $2,457. The debt in allegation 1.c is for this
same creditor and is included in the payment plan.13
Applicant admitted the debts in SOR allegations 1.f, 1.k, 1.n, and 1.p. Allegation
1.k relates to a power bill for the house in State A, which he sold in 2009. His settlement
documents reflect that he paid the town in which he lived nearly $1,000 on a delinquent
water bill and $460 on an interim utility bill. Applicant believed he had resolved this debt.
However, after the hearing, he contacted the creditor listed on the SOR. The creditor
said it would not accept a payment from him, then gave him the name of an individual to
contact about payment. Applicant sent an email to two email accounts for the individual,
and both emails were returned as undeliverable. The creditor continues to decline to
accept a payment from him. He asked for information on how to resolve this bill.
Applicant believes the three remaining bills may be medical bills related to care for his
daughter or former wife. He attempted to contact these creditors by telephone six
months before the hearing, but was unable to speak with someone or leave a message
to verify the original owner of the debts. He will pay the debts once he verifies the debts
are his. He has not provided payment on any of these debts.14
Concerning the debts in SOR allegations 1.h ($7,686), 1.i ($9,070) and 1.j
($8,970), which are listed as owed by the same creditor bank, these three debts are
listed on the December 2013 credit report as closed and charge-off by the bank creditor.
The credit report also reflects that the bank creditor sold the debt in allegation 1.h to
another creditor. The new owner of the debt is not listed on the credit reports in the
record. The bank creditor sold the debt in allegation 1.j to the credit agency identified in
GE 3 - GE 5.15
GE 3 - GE 5; Tr. 49, 55-56.16
AE N; AE U.17
Response to the SOR; GE 3 - GE 5.18
AE V.19
AE B; Tr. 25-26, 84.20
6
allegations 1.q through 1.t. After a careful review of the information in the creditor
reports, the debt in allegation 1.q is the same as the debt in 1.j.  15
The bank creditor in SOR allegation 1.e ($1,121) sold the debt to the creditor in
SOR allegation 1.t ($1,184). These two debts are the same debt. The May 2015 credit
report indicated a second federal tax lien (not alleged) in the amount of $2,743. At the
hearing, Applicant stated that this was the original amount of the lien filed against him
for the tax year 2008. He believes this lien is resolved.  16
The debt resolution company has agreed to resolve the following SOR debts: 1.b
($773), 1.c ($2,301), 1.d ($18,846), 1.g ($497), 1.m ($1,804), 1.o ($1,066), 1.q
($10,435), 1.r ($1,312), 1.s ($840), and 1.t ($1,184). These debts totaled $40,518. The
amount of debt owed as listed with the debt resolution company does show amounts
owed on several of the debts that are higher than the amount shown in the SOR. The
debt resolution company has made some small payments on these debts.17
The 2013 and 2015 credit reports indicate that Applicant disputed the debts in
SOR allegations 1.b - 1.d, 1.n, and 1.q - 1.t. The credit reports do not reflect if his
disputes were investigated and resolved. Applicant admitted these debts and is working
on a resolution of the debts.  18
Applicant provided a budget. His net monthly income totals $9,400. His monthly
expenses include $2,265 for rent, $630 for utilities, $490 for phones, cable and internet,
$330 for security, lawn, and household, $750 for food, $2,120 for car loans, gasoline,
registration, and insurance, $400 for college costs, $500 for credit card payments, $972
for debt payoff, $100 for medical costs, and $250 for miscellaneous expenses. His
monthly expenses total $8,807. He has an additional $593 for payment of debts not
covered above.19
Applicant acknowledged that he had not made any payments on most of his SOR
credit debts since 2010. He prioritized the court-directed payments and his tax debt for
resolution before working on a solution to the other debts. He did not mention how much
he spent on attorney fees for his divorce, but he has incurred attorney fees. The court
directed his former wife to pay $2,000 of his attorney fees and there is no evidence that
she did.20
7
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
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).  
8
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
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; and
(c) a history of not meeting financial obligations. 
Applicant developed significant financial problems when he and his wife divorced.
Most of the debts have not been resolved. These two disqualifying conditions apply.
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:
(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;
(d) the individual initiated a good-faith effort to repay overdue creditors or
otherwise resolve debts; and
(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’s financial problems began when he and his former wife separated and
divorced. As part of his divorce, he paid child support, alimony, and counseling costs,
9
which increased his routine monthly expenses by at least $3,000, leaving less money to
pay credit card debt. He exercised good judgment when he decided to comply with the
court ordered payments, even though these payments impacted his ability to pay all his
other debts. He sold his house in State A at about the time his divorce finalized, which
relieved this debt burden and showed good judgment.
He always filed his income tax returns. His tax debt arose from the actions of his
former wife just before their divorced finalized. Without his agreement, she took money
from his retirement accounts long before he would have been legally able to remove the
money without a penalty. The early removal of this money created a tax debt, which
Applicant anticipated. He made sure that his divorce decree addressed this problem
and that his former wife would be responsible for any tax deficiency assessed because
of her actions. Because she took the money, Applicant acted reasonably by having the
court specifically address his former wife’s responsibility for any tax debt and by
attempting through the court to enforce his wife’s obligation on the tax debt. AG ¶ 20(b)
applies fully to allegations 1.a and 1.l and applies partially to the remaining debts. 
Applicant tried on his own to resolve his remaining debts after concluding his
court obligated payments. His efforts began about the same time he received the SOR.
After his unsuccessful efforts to negotiate payment plans with his creditors, he
contacted a debt resolution company. He eventually retained the company, which has
agreed to resolve 10 SOR debts. He paid the tax debt his former wife owed under an
agreement developed with the IRS several years ago, and he established that he
resolved the mortgage debt many years ago. Mitigation applies under 20(b)  and 20(d)
to allegations 1.b - 1.e, 1.j, 1.k - 1.m, 1.o, and 1.q - 1.t.
Applicant disputed many debts with the credit reporting agencies. No reason has
been given for these disputes. Since Applicant has admitted these debts, and the debts
are part of his payment plan, AG ¶ 20(e) is not applicable.
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. 
10
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,
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. 
In assessing whether an applicant has established mitigation under Guideline F,
the Appeal Board provided the following guidance in ISCR Case No. 07-06482 at 3
(App. Bd. May 21, 2008):
In evaluating Guideline F cases, the Board has previously noted that the
concept of “‘meaningful track record’ necessarily includes evidence of
actual debt reduction through payment of debts.” See, e.g., ISCR Case
No. 05-01920 at 5 (App. Bd. Mar. 1, 2007). However, an applicant is not
required, as a matter of law, to establish that he has paid off each and
every debt listed in the SOR. See, e.g., ISCR Case No. 02-25499 at 2
(App. Bd. Jun. 5, 2006). All that is required is that an applicant
demonstrate that he has “. . . established a plan to resolve his financial
problems and taken significant actions to implement that plan.” See, e.g.,
ISCR Case No. 04-09684 at 2 (App. Bd. Jul. 6, 2006). The Judge can
reasonably consider the entirety of an applicant’s financial situation and
his actions in evaluating the extent to which that applicant’s plan for the
reduction of his outstanding indebtedness is credible and realistic. See
Directive ¶ E2.2(a) (“Available, reliable information about the person, past
and present, favorable and unfavorable, should be considered in reaching
a determination.”) There is no requirement that a plan provide for
payments on all outstanding debts simultaneously. Rather, a reasonable
plan (and concomitant conduct) may provide for the payment of such
debts one at a time. See, e.g., ISCR Case No. 06-25584 at 4 (App. Bd.
Apr. 4, 2008). Likewise, there is no requirement that the first debts actually
paid in furtherance of a reasonable debt plan be the ones listed in the
SOR.
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. Applicant
endured a highly stressful and emotional divorce. He made the court ordered payments
and his daughter his priority during this time. His daughter continues to live with him and
attends college. The court-mandated expenses seriously impacted Applicant’s ability to
pay all his debt because he still had to pay rent, utilities, phones, food, insurance and
other ordinary daily living expenses. He allowed his credit cards to go into default as
11
well as his second house while he met his other obligations. He always filed his tax
returns and when his former wife refused to pay the tax debt as agreed, he assumed
responsibility for it. His other unpaid debts he set aside as his former wife had taken all
his assets, leaving him without money for debt payment. With the conclusion of his court
ordered obligations, he has started the long process of identifying and paying his
remaining debts. Most significantly, he has taken affirmative action to pay or resolve
most of the delinquent debts raising security concerns. He retained a company to help
him achieve this goal. He has a plan to resolve many of the SOR debts, but not four
small debts. Applicant’s statement that he will pay these debts once he determines they
are his is accepted as credible in light of the efforts taken to resolve his debts. His
current bills are paid timely, and he manages his income. He has not incurred new
unpaid debt since his divorce.
Applicant remains single. For the last six or seven years, he focused his attention
on providing a stable home environment for his daughter. (See AG & 2(a)(6).) Four
small debts are unpaid, and three larger debts belonging to the same creditor are not
listed in his debt plan. Applicant’s statement that the creditor told the debt resolution
company that Applicant owed about $2,400 is credible because throughout this process
Appellant has been honest about the events and his choices. While he has not paid all
his debts and he is still trying to resolve some of his debts, these debts cannot be a
source of improper pressure or duress. Of course, the issue is not simply whether all his
debts are paid: it is whether his financial circumstances raise concerns about his fitness
to hold a position of trust. While some debts remain unpaid, they are insufficient to raise
security concerns. (See AG & 2(a)(1).) Appellant is a responsible and hard working
individual who has exercised good decision making and judgment during a major life
changing event. He will continue to exercise good judgment.
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
Subparagraphs 1.a-1.t: For Applicant
12
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 a security clearance is granted.
                                                              
MARY E. HENRY
Administrative Judge