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                        DEPARTMENT OF DEFENSE    
         DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
) 
  )  ISCR Case No. 15-03875 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Gina L. Marine, Esq., Department Counsel 
For Applicant: Pro se 
 
 
 
______________ 
 
Decision 
______________ 
 
MATCHINSKI, Elizabeth M., Administrative Judge: 
 
Applicant and his spouse defaulted on a joint student loan with a balance of $50,692. 
Two other student loans, which were cosigned by Applicant for his spouse, were charged 
off for $9,342 and $7,346 in 2012. They have made monthly payments consistently since 
May 2012 on the largest loan, but repayment plans for the other loans were not established 
until February 2016, when a collection agency proposed a settlement. Applicant and his 
spouse are paying their monthly expenses on time, but available information is not 
sufficient for me to reasonably conclude that they can be counted on to address the 
student loans without falling behind on other debts. Clearance is denied. 
 
 Statement of the Case  
 
On December 3, 2015, the Department of Defense Consolidated Adjudications 
Facility (DOD CAF) issued a Statement of Reasons (SOR) to Applicant, detailing the 
security concerns under Guideline F, financial considerations, and explaining why it was 
unable to find that it is clearly consistent with the national interest to grant him security 
clearance eligibility. The DOD CAF took the action 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 
 
 
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(January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) effective 
within the DOD on September 1, 2006. 
 
Applicant responded to the SOR allegations on December 24, 2015, and he 
requested a decision on the written record without a hearing. On January 27, 2016, the 
Government submitted a File of Relevant Material (FORM) consisting of seven documents 
(Items 1-7), including Applicant’s answer to the SOR (Item 2). On January 29, 2016, the 
Defense Office of Hearings and Appeals (DOHA) forwarded a copy of the FORM to 
Applicant and instructed him to respond within 30 days of receipt. Applicant received the 
FORM on February 5, 2016. Applicant submitted an undated rebuttal to the SOR, which 
was received by DOHA on March 3, 2016.1 On March 4, 2016, Department Counsel 
indicated that the Government did not object to the consideration of Applicant’s response 
to the FORM. On April 22, 2016, the case was assigned to me to consider whether it is 
clearly consistent with the national interest to grant a security clearance for Applicant. 
Applicant’s rebuttal to the FORM is hereby incorporated in the record as Applicant Exhibit 
(AE) A. 
 
Summary of SOR Allegations and Response 
 
 The SOR alleges that Applicant owed three student loans, which had been charged 
off for $7,346 (SOR ¶ 1.a), $55,137 (SOR ¶ 1.b), and $9,342 (SOR ¶ 1.c), and were 
delinquent as of December 3, 2015. When he answered the SOR (Item 2), Applicant 
indicated that the debts had been charged off in 2012 when his spouse was laid off for six 
months. 
 
Findings of Fact 
 
After considering the FORM and Applicant’s rebuttal (AE A), I make the following 
findings of fact. 
 
Applicant is a 37-year-old college graduate, who has worked for a defense 
contractor since January 2003. He seeks his first DOD security clearance on application 
submitted in April 2013. (Item 3.) 
 
Applicant and his spouse married in September 2005. (Item 4.) They have two 
children born in August 2008 and November 2010. Applicant’s spouse also has a 20-year-
old son that they raised. (Item 3.) 
 
Applicant and his spouse purchased their current residence in July 2008 with a 
mortgage loan of $218,641. (Item 7.) They paid off the loan by refinancing in January 2014 
with a new lender. They obtained a $202,750 mortgage and lowered their monthly 
mortgage payment from $1,794 to $1,626. (Item 5.) 
 
                                                 
1 It is unclear whether Applicant or someone else prepared his rebuttal. Applicant and his spouse are both 
referred to in the third person. 
 
 3 
Applicant earned his bachelor’s degree in August 2001. (Item 3.) He paid for his 
education in part with student loans. Between September 1997 and September 2000, 
Applicant obtained four student loans totaling $14,250. His loans were current when they 
were consolidated in September 2003 for $15,898. Applicant has paid his student-loan 
debt on time at $119 per month. As of September 2015, the loan balance was $4,609. 
(Items 7.)  
 
Applicant cosigned or opened jointly with his spouse student loans for her, including 
some loans not listed in the SOR.2 After completing her education in August 2008, she was 
employed full time as a nurse from October 2008 until November 2010, when she gave 
birth to their younger child. While on maternity leave for three months, Applicant’s spouse 
received 60% of her regular pay. In May 2011, she took a job at less pay because of some 
personal family issues. (AE A.) By 2012, they were struggling to pay their household 
expenses, which took priority over her student loans. Available credit reports show that 
some of her student loans for which Applicant is liable jointly or as a cosigner were charged 
off in 2012, as follows. 
 
Student loan #1 (SOR ¶ 1.a), opened in March 2007 for $6,591 with Applicant as 
cosigner, was charged off for $7,346 in October 2012. (Items 5-7.) A subsequent 
purchaser of the debt filed for a judgment of $14,558 against Applicant and his spouse in 
late 2013, claiming default on the loan since May 2011. In January 2014, Applicant and his 
spouse countered that they had made some payments, including on July 23, 2012, to the 
original lender. They contested the validity of the lawsuit for lack of contract with the debt 
purchaser. On December 17, 2015, the debt purchaser filed for voluntary dismissal of the 
case without prejudice.3 (Item 2.) The loan debt was sold to a collection agency. (AE A.) 
 
Student loan #2 (SOR ¶ 1.b), a joint loan opened in September 2006 for $47,140 
(AE A), was charged off for $50,692 in March 2012. (Items 5-7.) Payments were made 
toward the debt in 2011, but not on a consistent basis. Applicant and his spouse paid $383 
in March 2011 and April 2011; $374 in June 2011; and $384 in October 2011 and 
November 2011. After the debt was charged off, they made $200 monthly payments from 
May 2012 to August 2012. From September 2012 through August 2013, they made $50 
monthly payments, which were not sufficient to cover the interest on the loan. Under terms 
arranged by the lender, they paid $500 in September 2013 and again in October 2013. 
From November 2013 through at least February 2016, they have paid $276 per month with 
no missed payments. Their payments have been applied toward interest only since June 
2012. As of March 1, 2016, the loan had an outstanding balance of $53,757. (AE A.) 
 
                                                 
2 A student loan, opened in February 2006 for $3,960 with Applicant as cosigner, was charged off for $3,684 in 
September 2011. In September 2013, he and his spouse settled the debt on a payment of $2,248. (Item 5.)  
 
3 Applicant initially believed that the claim for a judgment on student loan #3 had also been dismissed. (Item 
2.) The record contains the request from the purchaser to dismiss its claim without prejudice as to student 
loan #1. There is no such document for student loan #3 in the record. A dismissal without prejudice would not 
preclude the debt holder from re-filing for a judgment in the future. However, the student loans have since 
been sold. (AE A.) 
 
 
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Student loan #3 (SOR ¶ 1.c), opened in August 2006 for $6,557 with Applicant as 
cosigner, was charged off in May 2012 for $9,342. (Items 5-7.) The debt was sold in 2013, 
and the purchaser filed for a judgment of $9,317 against Applicant and his spouse in late 
2013, alleging default on the loan since May 2011. In January 2014, Applicant and his 
spouse contested the claim because of no contractual relationship with the purchaser, and 
the debt was no longer legally collectible because of the statute of limitations. (Item 2.) The 
debt was acquired by a collection agency in December 2015. (AE A.) 
 
When he answered the SOR, Applicant attributed the charge-offs to his spouse 
being laid off for approximately six months after the birth of their second child. (Item 2.) In 
response to the FORM, he explained that his spouse returned to work after her maternity 
leave; that she had to take another job at less income in May 2011 because of personal 
family issues; and that he had some financial struggles “when his spouse was unemployed 
from June 2012-July 2012 while she was presented with some personal family issues,” and 
that she has been employed full time at a hospital since March 2013. (AE A.) It is unclear 
whether Applicant’s spouse earned any income from June 2012 until March 2013, when 
she returned to work full time. The record contains no detail about their income, expenses, 
or the personal family circumstances that affected their household. 
 
Needing a security clearance for his duties, Applicant completed and certified to the 
accuracy of a Questionnaire for National Security Positions (SF 86) on April 5, 2013.4 In 
response to inquiries concerning any delinquency involving routine accounts, Applicant 
indicated that three of his spouse’s student loans, on which he was legally liable, were over 
120 days delinquent. He estimated the debt at only $3,000 and explained that they were 
unable to make payments on some of her student loans while she was unemployed for six 
to nine months around January 2011. He added that he was “working on payment plans 
and plans to get student loans current.” (Item 3.) 
 
As of April 2013, Applicant and his spouse were 30 days past due (one payment of 
$714) on a vehicle loan obtained in November 2010 for $43,354. They paid off the loan in 
August 2014, when they acquired a new vehicle. (Item 6.) Applicant’s credit record showed 
no additional delinquencies apart from his spouse’s student loans, for which he was legally 
liable as co-borrower or cosigner. (Item 7.) 
 
On May 8, 2013, Applicant was interviewed by an authorized investigator for the 
Office of Personnel Management (OPM). About his spouse’s student loans, he indicated 
that he was making $50 monthly payments toward student loan #2, which was current and 
which he inexplicably claimed had a balance of only $7,500. He admitted that his spouse’s 
student loans #1 and #3 were past due, but he did not recall their balances. He expressed 
intent to contact the lender in SOR ¶ 1.a about a payment plan to resolve student loan #1. 
(Item 4.) 
 
There is no evidence that Applicant took any action to address student loans #1 and 
#3 while the judgment actions were pending in court. Applicant indicates that neither he nor 
                                                 
4 The SF 86, included in the FORM as Item 3, is missing pages 1 through 4, which are largely instructional. 
Sections 1 through 29 are in the file.  
 
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his spouse was able to resolve the financial obligations at that time because of the 
discrepancies in the amounts owed and the “lender” declined to speak with them about 
repayment. (AE A.) 
 
Applicant and his spouse took on new debt in 2014. Since May 2014, they have 
made monthly payments of $127 to a furniture retailer toward a debt that had a balance of 
$1,137 as of November 2015. In July 2014, they opened a car loan of $28,260, to be 
repaid at $567 per month for 73 months. In October 2014, they opened a car loan of 
$18,555, to be repaid at $351 per month for 73 months. (Item 5.) 
 
On December 3, 2015, the DOD CAF issued an SOR to Applicant alleging 
delinquent student loan balances of $7,346 on student loan #1 (SOR ¶ 1.a), $55,137 on 
student loan #2 (SOR ¶ 1.b), and $9,342 on student loan #3 (SOR ¶ 1.c). (Item 1.) 
Applicant responded to the SOR on December 23, 2015. He provided documentation of 
the judgment filings for student loans #1 and #3 in 2013, and of a notice of dismissal 
without prejudice in December 2015 of the case involving student loan #1. Applicant 
mistakenly assumed that the notice of dismissal also applied to student loan #3. (AE A.) 
Applicant stated with respect to both student loans, “We do not know what the status of the 
loan is or who holds it. [If] someone contacts us we are willing to setup a payment plan.” 
Concerning his claims of payment of student loan #2, Applicant provided documentation 
showing that his bank account would be debited for $276 on November 30, 2015, toward 
the account’s $53,757 balance. (Item 2.) 
 
In December 2015, student loans #1 and #3 were acquired by a collection agency, 
who offered to settle both loans for a lump-sum payment that they could not afford. The 
collection agency then proposed a settlement of $2,000 upfront and then monthly 
payments for two years. Instead, in February 2016, Applicant or his spouse arranged for 
$75 payments on each loan by pre-authorized debit for three months, which is all that they 
can afford at this time. As of February 22, 2016, they owed $16,431 (unpaid principal 
$13,056) on student loan #1 and $10,515 ($8,355 in unpaid principal) on student loan #3. 
According to Applicant, he and his spouse will be contacted about the monthly payment 
amount every three months, and their payments will increase over time until the debts are 
resolved. (AE A.) 
 
As of November 2015, Applicant and his spouse’s mortgage and car loans are being 
paid on time. Applicant has also been making monthly payments of $118 on his 
consolidated student loan balance of $4,609, $51 on a student loan for his spouse of 
$4,300, $183 on his flexible spending credit-card account balance of $8,789, and $127 on 
the furniture debt. (Item 5.)  
 
Applicant believes he has his financial problems under control. While he plans on 
following a “strategic budget” to improve his financial situation, he did not elaborate as to 
his household income or expenses. His spouse is applying for a government program that 
forgives student loan debt. (AE A.) 
 
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Policies 
 
The U.S. Supreme Court has recognized the substantial discretion the Executive 
Branch has in regulating access to information pertaining to national security, emphasizing 
that “no one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 
U.S. 518, 528 (1988). 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 required to 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 overall 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, 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 to obtain 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. 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). 
 
Analysis 
 
Guideline F, Financial Considerations 
 
The security concern about financial considerations is articulated in AG ¶ 18: 
 
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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. 
 
 The Guideline F concerns are established by Applicant’s and his spouse’s default of 
three student loans for her nursing studies.  Student loans for which Applicant is liable as a 
joint borrower or as a cosigner for his spouse were charged off for $7,346 in October 2012 
(SOR ¶ 1.a), $50,692 in March 2012 (SOR ¶ 1.b), and $9,342 in May 2012 (SOR ¶ 1.c). 
Disqualifying conditions AG ¶ 19(a), “inability or unwillingness to satisfy debts,” and AG ¶ 
19(c), “a history of not meeting financial obligations,” are implicated. 
 
The student loans at issue were obtained in 2006 and 2007, and there is no record 
of serious delinquency on other accounts. Even so, it is difficult to apply AG ¶ 20(a), “the 
behavior happened so long ago, was so infrequent, or occurred under circumstances that it 
is unlikely to recur and does not cast doubt on the individual’s current, reliability, or good 
judgment.” As of the date of the SOR, all of the loans were in delinquency status, including 
student loan #2 that they have been repaying on a monthly basis. 
 
Applicant attributes the student loan defaults to “a lot of financial struggles in the 
years of 2011-2012, not only from the birth of their third child but as well as other personal 
burdens that they endured during that time.” (AE A.) Applicant did not elaborate about their 
burdens, financial or otherwise, apart from indicating that his spouse received 60% of her 
regular pay during three months of maternity leave; that she had to take a new job at less 
income in May 2011 because of “personal family issues”; and that she was unemployed for 
a time, which he variously estimated at six months (Item 2) to six to nine months. (Item 3.) 
In rebuttal to the FORM, he indicated that he faced some financial struggles when his 
spouse was unemployed from June 2012 to July 2012. (AE A.) An unexpected layoff or 
voluntary unemployment to address unexpected family issues could implicate AG ¶ 20(b), 
but the mitigating factor requires that an individual act responsibly, as follows: 
 
(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. 
 
Applicant did not provide details about his spouse’s income loss, their household 
financial obligations, or their personal burdens. Generalized statements of financial 
struggle from the birth of a child and other personal burdens are not enough to fully 
mitigate the student loan defaults under AG ¶ 20(b). From the limited information available, 
it is difficult to conclude that he did all he could to address the student loans under the 
circumstances that he faced.  
 
 
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Applicant is credited with the consistent payments made toward student loan #2 
since May 2012, initially at $200 a month. The payments were not sustainable in light of his 
spouse’s apparent unemployment that summer. From September 2012 through August 
2013, they paid $50 a month, which did not cover the interest due on the loan, but it shows 
consistency in addressing the debt. They then made two payments of $500 required by the 
creditor to accept $276 per month in repayment. As of late February 2016, they have made 
28 payments of $276, which have been applied solely to interest due on the debt. With an 
outstanding balance of $53,757 on the loan, it is going to be years before the debt is paid 
off. Even so, Applicant has established a sufficient record of repayment to apply 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,” and AG ¶ 20(d), 
“the individual initiated a good-faith effort to repay overdue creditors or otherwise resolve 
debts,” to student loan #2. 
 
Neither AG ¶ 20(c) nor AG ¶ 20(d) is adequately established as to student loans #1 
and #3. Applicant and his spouse made no effort to repay the loans after his spouse 
acquired full-time employment in March 2013, which may well have been a factor in the 
purchaser filing for judgments and then refusing to discuss repayment with them while the 
lawsuits were pending. Applicant and his spouse cannot reasonably be faulted for not 
making payments toward the student loans before verification of contested balance 
amounts. However, the evidence also shows that they incurred a debt with a home 
furnishing retailer and opened two new auto loans in 2014 when they were facing possible 
judgment awards against them for $23,876 in delinquent student-loan debt.  With the auto 
loan obtained in August 2014, it appears that they reduced their monthly car payment from 
$714 to $567, but they then increased their monthly obligation to $918 by taking on a $351 
car payment for another vehicle in October 2014. These obligations have compromised 
Applicant’s and his spouse’s ability to address student loans #1 and #3. Applicant and his 
spouse could not afford the initial settlement terms offered by the collection company that 
acquired the student-loan debts in December 2015. They showed some good faith in 
arranging to make three monthly payments of $75 toward each loan starting in late 
February 2016, but there is no evidence that any of those payments have been made. 
 
As of February 2016, the delinquent student loans in the SOR had an aggregate 
balance of $80,703, which is a substantial debt burden. Student loans are an investment in 
one’s future and do not carry the same judgment concerns as would excessive credit card 
debt. The consistent payments toward student loan #2 suggest that Applicant can be 
counted on to make payments toward student loans #1 and #3, provided he has the 
income to do so. Applicant is currently meeting their household expenses and obligations 
under a “strict, strategic budget.” With little information about Applicant’s household 
expenses in the record and no information about income or any savings, it is difficult to 
assess the financial impact of the $150 in monthly payments promised to the collection 
agency holding student loans #1 and #3. The financial considerations concerns are not yet 
fully mitigated. 
 
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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 his conduct and 
all the 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. 
 
The analysis under Guideline F is incorporated in my whole-person assessment, but 
some aspects warrant additional comment. Applicant indicated in rebuttal to the FORM that 
he and his spouse have already made “incredible strides in repairing their debt,” and he is 
finally in a situation where he can make payments on all of his debts. He and his spouse 
apparently do not have the financial resources to commit to more than $150 per month 
total toward student loans #1 and #3. Applicant is not required to establish that he has paid 
off each debt in the SOR, or even that the first debts paid be those in the SOR.5 Even so, 
there must be adequate assurances that his financial difficulties are not likely to recur. 
Applicant addressed some of the concerns of the Government by presenting the evidence 
of his payments toward student loan #2. Available credit reports shed some light on his 
finances, but available information falls short of enabling a positive predictive judgment that 
his financial situation is no longer of security concern. Should Applicant establish a 
sustained track record of meeting all his obligations, including student loans #1 and #3, he 
                                                 
5 The DOHA Appeal Board stated in ISCR Case No. 07-06482, decided on May 21, 2008, in part: 
 
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. 
 
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may be able to show in the future that his financial problems are clearly under control. After 
considering all the evidence before me, I cannot conclude that it is clearly consistent with 
the national interest to grant Applicant security clearance eligibility at this time. 
 
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:  AGAINST APPLICANT 
 
Subparagraph 1.a:  Against Applicant 
Subparagraph 1.b:  For Applicant 
Subparagraph 1.c:  Against Applicant 
 
Conclusion 
 
In light of all of the circumstances presented by the record in this case, it is not 
clearly consistent with the national interest to grant Applicant eligibility for a security 
clearance. Eligibility for access to classified information is denied. 
 
 
________________________ 
Elizabeth M. Matchinski 
Administrative Judge