KEYWORD: Guideline F
DIGEST: Applicant has several delinquent debts.  Applicant attributed her problems to several
periods of unemployment.  Her credit reports show that her debts were incurred over a number of
years.  She did not provide information about how much, if any, of her savings she utilized for
debt payment.  The Judge found that two of the nine SOR debts were either resolved or were
being resolved.  For the remainder, however, he found that they have not been paid.  Adverse
decision affirmed.
CASENO: 15-01588.a1
DATE: 06/17/2016
DATE: June 17, 2016
In Re:
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Applicant for Security Clearance
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ISCR Case No. 15-01588
APPEAL BOARD DECISION
APPEARANCES
FOR GOVERNMENT
James B. Norman, Esq., Chief Department Counsel
FOR APPLICANT
Shirin Shokrollahi, Esq.
The Department of Defense (DoD) declined to grant Applicant a security clearance.  On
September 1, 2015, 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 March 31, 2016, after considering the record, Defense Office of Hearings
and Appeals (DOHA) Administrative Judge Philip S. Howe denied Applicant’s request for a security
clearance.  Applicant appealed pursuant to Directive ¶¶  E3.1.28 and E3.1.30.
Applicant raised the following issues on appeal: whether the Judge erred in his application
of the mitigating conditions and whether the Judge’s whole-person analysis was erroneous. 
Consistent with the following, we affirm. 
The Judge’s Findings of Fact
Applicant has several delinquent debts, for credit cards, cable television services, etc. 
Applicant attributed her problems to several periods of unemployment.  She also stated that she
suffered an unspecified financial hardship.  Her credit reports show that her debts were incurred over
a number of years, including some when she was unemployed.  Applicant traveled outside the U.S.
in 2006 and again in 2007.  She did not disclose how much she spent on these trips.  She did not
provide information about how much, if any, of her savings she utilized for debt payment.  The
Judge found that two of the nine SOR debts were either resolved or were being resolved.  For the
remainder, however, he found that they have not been paid.  Applicant provided no evidence that
she had received credit counseling.  
The Judge’s Analysis
The Judge concluded that Applicant had not provided enough evidence to mitigate the
concerns raised by her financial problems.  He stated that, over time, Applicant had incurred debts
that she had no reasonable hope of paying, and she went on vacations and spent money that could
have been used for debts resolution.
In the whole-person analysis, the Judge reiterated that Applicant had failed to resolve all but
two of her debts, leaving her vulnerable to pressure, coercion, exploitation, or duress based on the
extent of her financial problems.  He stated that she showed poor judgment by incurring the debts
and then by failing to pay them over a course of several years.
Discussion
Applicant’s brief cites to matters that are not included in the record.  We cannot consider new
evidence on appeal.  Directive ¶ E3.1.29.  Applicant cites to record evidence that she believes
supports her case for a clearance.  However, her arguments are not enough to rebut the presumption
that the Judge considered all of the evidence in the record or to show that the Judge weighed the
evidence in a manner that was arbitrary, capricious, or contrary to law.  See, e.g., ISCR Case No.
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14-05795 at 2, 3 (App. Bd. Apr. 26, 2016).  We conclude that the Judge’s whole person analysis
complies with the requirements of Directive ¶ 6.3, in that the Judge considered the totality of the
evidence in reaching his decision. See, e.g., ISCR Case No. 15-00424 at 2-3 (App. Bd. Apr. 20,
2016). 
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: James E. Moody                  
James E. Moody
Administrative Judge
Member, Appeal Board
Signed: William S. Fields                
William S. Fields
Administrative Judge
Member, Appeal Board
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