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   DEPARTMENT OF DEFENSE 
       DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
In the matter of: ) 
 ) 
     )  ISCR Case No. 15-01091 
  ) 
Applicant for Security Clearance  ) 
 
 
Appearances 
 
For Government: Philip J. Katauskas, Esq., Department Counsel 
For Applicant: Pro se 
 
 
___________ 
 
Decision 
___________ 
 
HARVEY, Mark, Administrative Judge: 
 
 Applicant made sufficient progress resolving the 23 delinquent debts totaling 
$37,524 alleged in her statement of reasons (SOR). She paid four SOR debts; two SOR 
debts are duplications; and three SOR debts were removed from her credit report after 
she challenged them. She promised to continue payments on her remaining SOR debts, 
which total $8,568. Financial considerations security concerns are mitigated. Eligibility for 
access to classified information is granted.       
  
Statement of the Case 
  
On July 11, 2012, Applicant signed her Questionnaire for National Security 
Positions (SF 86) or security clearance application (SCA). (Government Exhibit (GE) 1) 
On December 4, 2015, the Department of Defense (DOD) Consolidated Adjudications 
Facility (CAF) issued an SOR to Applicant pursuant to Executive Order (Exec. Or.) 10865, 
Safeguarding Classified Information Within Industry; DOD Directive 5220.6, Defense 
Industrial Personnel Security Clearance Review Program (Directive); and the 
Adjudicative Guidelines for Determining Eligibility for Access to Classified Information 
(AG), which became effective on September 1, 2006.  
 
The SOR detailed reasons why the DOD CAF did not find under the Directive that 
it is clearly consistent with the national interest to grant or continue a security clearance 
for Applicant, and recommended referral to an administrative judge to determine whether 
   
 
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a clearance should be granted, continued, denied, or revoked. (Hearing Exhibit (HE) 2) 
Specifically, the SOR set forth security concerns arising under Guideline F (financial 
considerations). 
 
On March 7, 2016, Applicant responded to the SOR and requested a hearing. On 
June 27, 2016, Department Counsel was ready to proceed. On August 15, 2016, the case 
was assigned to me. On September 12, 2016, the Defense Office of Hearings and 
Appeals (DOHA) issued a notice of hearing, setting the hearing for October 7, 2016. (HE 
1) The hearing was held as scheduled.   
  
During the hearing, Department Counsel offered 5 exhibits; Applicant offered 11 
exhibits; and all proffered exhibits were admitted without objection. (Tr. 17-23, 36-38, 66-
67; GE 1-5; Applicant Exhibits (AE) A-K) On October 18, 2016, DOHA received a copy of 
the transcript of the hearing. On November 14, 2016, Applicant offered four additional 
exhibits, which were admitted without objection. (AE L-AE O) The record closed on 
November 14, 2016. (Tr. 86) 
 
Findings of Fact1 
 
 In Applicant’s SOR response, she admitted to, at some point, owing the debts in 
SOR ¶¶ 1.a through 1.c and 1.e through 1.w. She also provided extenuating and 
mitigating information. Applicant’s admissions are accepted as findings of fact.  
 
Applicant is a 31-year-old security specialist, who has worked for her employer 
since April 2014. (Tr. 6, 29; GE 1) In 2012, she received her General Educational 
Development (GED) certificate. (Tr. 7) She has not attended college. (Tr. 7) She has not 
served in the U.S. Armed Forces. (Tr. 7) She has never married, and her three children 
are ages four months, six years, and 12 years. (Tr. 7-8) Applicant has custody of all of 
her children.  
 
Financial Considerations 
 
 Several years ago, Applicant had some debts she was unable to pay while she 
was unemployed. (Tr. 27) Applicant’s medical debts resulted from obtaining medical care 
when she did not have medical insurance, or the health care provider did not accept her 
medical insurance. (Tr. 25) She had a payment plan to address her medical debts. (Tr. 
25) She has difficulty supporting herself and her three children on her income. (Tr. 31) 
From July 2015 to September 2016, she employed a law firm to seek verifying information 
for the debts on her credit reports. (Tr. 47-48, 72) She paid the law firm $100 monthly. 
(Tr. 48) Applicant is receiving financial counseling and assistance from her brother-in-law 
who has expertise in financial matters. (Tr. 65-66) He helped her establish a budget. (Tr. 
66) 
 
                                            
1Some details have been excluded to protect Applicant’s right to privacy. Specific information is 
available in the cited exhibits. 
   
 
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 Applicant’s history of delinquent debt is documented in her credit reports, SOR 
response, and hearing record. The status of her SOR debts is as follows: 
 
 SOR ¶ 1.a alleges a collection debt owed to a credit union for $21,270. In 2006, 
Applicant purchased a vehicle; in 2009, she was unable to continue making the required 
monthly payments; and the creditor repossessed her vehicle. (Tr. 68-69) On September 
15, 2016, the collection agent offered to settle this debt for $2,000. (AE A) The creditor 
disclosed the debt was not collectible due to the passage of the statute of limitations. (AE 
A) On September 19, 2016, the creditor acknowledged receipt of $2,000 and wrote that 
the debt was settled. (AE A) 
 
SOR ¶¶ 1.b through 1.h, 1.j through 1.o, 1.t, and 1.u alleges 15 delinquent medical 
debts totaling $10,713 for $1,145, $592, $546, $540, $540, $500, $442, $366, $340, 
$102, $85, $53, $50, $1,864, and $3,548. On June 27, 2016, Applicant settled and paid 
a medical debt for $200. (Tr. 23; AE B; AE D) She asked for verification of the debts in 
SOR ¶¶ 1.d ($546) and 1.h ($442), and the creditor elected to delete them from her credit 
reports. (Tr. 33-35; AE B) In July 2016, Applicant made her first $50 payment to address 
a $450 medical debt. (Tr. 35; AE C) She has made additional $50 payments to her 
medical creditors, and she plans to continue making $50 payments. (Tr. 39; AE O) She 
is going to get a new credit report to assist in identifying some of the medical creditors. 
(Tr. 47, 55-57) The debts in SOR ¶¶ 1.t ($1,864) and 1.u ($3,548) are the same debt. (Tr. 
60-63) 
 
SOR ¶¶ 1.i and 1.w allege a collection debt for $436. They are the same debt. (Tr. 
53) Applicant contacted the creditor, and she received a settlement offer from the creditor. 
(Tr. 54) She plans to pay $357 to settle the debt. (Tr. 54) 
 
SOR ¶ 1.p alleges a judgment filed in 2010 for $1,742. The debt resulted when 
Applicant’s mother left the apartment before the lease was completed. (Tr. 41) The 
creditor filed a satisfaction with the court on February 11, 2015. (AE E) On September 26, 
2016, the creditor wrote that the debt was paid and her account is in good standing. (AE 
D)  
 
SOR ¶ 1.q alleges a judgment for $1,842. Applicant’s son was in the custody of 
his grandparents for a time, and Applicant was required to pay child support to them. (Tr. 
45) Applicant provided a receipt indicating on February 11, 2015, she paid $332 to the 
creditor. (Tr. 42-44; AE F) In February 2015, she arranged a direct payment from her 
salary to address this debt. (AE F) She currently has custody of her son. (Tr. 44-45) The 
account has a zero balance. (Tr. 46) 
 
SOR ¶¶ 1.r and 1.s allege telecommunications debts for $706 and $271. Applicant 
contacted the creditors; the creditor in SOR ¶ 1.r agreed she did not owe the debt; and 
the creditor promised to contact the credit reporting companies to have the negative entry 
removed from her credit report. (Tr. 58-59) Applicant received verification of the debt in 
SOR ¶ 1.s, and she intends to pay the debt in SOR ¶ 1.s. (Tr. 59-60; AE N) 
   
 
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SOR ¶ 1.v alleges a bank collection debt for $96. Applicant said she paid this debt. 
(Tr. 63-64) 
 
After her hearing, Applicant provided a personal financial statement. (AE M) Her 
monthly gross income is $1,866, and her net monthly remainder is negative $763. (AE M) 
Her son’s father passed away in August 2016, and he previously provided financial 
support to Applicant’s son. (AE M) She did not include an explanation about how she will 
continue to address her delinquent debts without additional income.  
 
Character Evidence 
 
Two managing security personnel and Applicant’s supervisors described her as 
honest, diligent, enthusiastic, detail oriented, trustworthy, responsible, reliable, and 
dedicated. (Tr. 76-84) Applicant’s brother-in-law, two friends of many years, and a 
consultant described her as an honest, diligent, trustworthy, intelligent, and dedicated. 
(AE H-AE K) Applicant is serious about repairing her credit and caring for her family. (AE 
H-AE K) Their statements support her access to classified information.         
 
Policies 
 
The U.S. Supreme Court has recognized the substantial discretion of the Executive 
Branch in regulating access to information pertaining to national security emphasizing, 
“no one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 U.S. 
518, 528 (1988). As Commander in Chief, the President has the authority to control 
access to information bearing on national security and to determine whether an individual 
is sufficiently trustworthy to have access to such information.” Id. at 527. The President 
has authorized the Secretary of Defense or his designee to grant applicant’s eligibility for 
access to classified information “only upon a finding that it is clearly consistent with the 
national interest to do so.” Exec. Or. 10865, Safeguarding Classified Information within 
Industry § 2 (Feb. 20, 1960), as amended.  
 
Eligibility for a security clearance is predicated upon the applicant meeting the 
criteria contained in the adjudicative guidelines. These guidelines are not inflexible rules 
of law. Instead, recognizing the complexities of human behavior, these guidelines are 
applied in conjunction with an evaluation of the whole person. An administrative judge’s 
overarching adjudicative goal is a fair, impartial, and commonsense decision. An 
administrative judge must consider all available, reliable information about the person, 
past and present, favorable and unfavorable.  
 
The Government reposes a high degree of trust and confidence in persons with 
access to classified information. This relationship transcends normal duty hours and 
endures throughout off-duty hours. Decisions include, by necessity, consideration of the 
possible risk the applicant may deliberately or inadvertently fail to safeguard classified 
information. Such decisions entail a certain degree of legally permissible extrapolation 
about potential, rather than actual, risk of compromise of classified information. Clearance 
decisions must be “in terms of the national interest and shall in no sense be a 
   
 
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determination as to the loyalty of the applicant concerned.” See Exec. Or. 10865 § 7. 
Thus, nothing in this decision should be construed to suggest that it is based, in whole or 
in part, on any express or implied determination about applicant’s allegiance, loyalty, or 
patriotism. It is merely an indication the applicant has not met the strict guidelines the 
President and the Secretary of Defense have established for issuing a clearance. 
  
 Initially, the Government must establish, by substantial evidence, conditions in the 
personal or professional history of the applicant that may disqualify the applicant from 
being eligible for access to classified information. The Government has the burden of 
establishing controverted facts alleged in the SOR. See Egan, 484 U.S. at 531. 
“Substantial evidence” is “more than a scintilla but less than a preponderance.” See v. 
Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines 
presume a nexus or rational connection between proven conduct under any of the criteria 
listed therein and an applicant’s security suitability. See ISCR Case No. 95-0611 at 2 
(App. Bd. May 2, 1996). 
 
Once the Government establishes a disqualifying condition by substantial 
evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the 
facts. Directive ¶ E3.1.15. An applicant “has the ultimate burden of demonstrating that it 
is clearly consistent with the national interest to grant or continue his security clearance.” 
ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002). The burden of disproving a 
mitigating condition never shifts to the Government. See ISCR Case No. 02-31154 at 5 
(App. Bd. Sep. 22, 2005). “[S]ecurity clearance determinations should err, if they must, 
on the side of denials.” Egan, 484 U.S. at 531; see AG ¶ 2(b). 
 
Analysis 
 
Financial Considerations 
 
AG ¶ 18 articulates the security concern for financial problems:  
 
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 Appeal Board explained the scope and rationale for the financial 
considerations security concern as follows: 
 
This concern is broader than the possibility that an applicant might 
knowingly compromise classified information in order to raise money in 
satisfaction of his or her debts. Rather, it requires a Judge to examine the 
totality of an applicant’s financial history and circumstances. The Judge 
must consider pertinent evidence regarding the applicant’s self-control, 
   
 
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judgment, and other qualities essential to protecting the national secrets as 
well as the vulnerabilities inherent in the circumstances. The Directive 
presumes a nexus between proven conduct under any of the Guidelines 
and an applicant’s security eligibility.  
 
ISCR Case No. 11-05365 at 3 (App. Bd. May 1, 2012) (citation omitted). 
 
AG ¶ 19 provides two disqualifying conditions that could raise a security concern 
and may be disqualifying in this case: “(a) inability or unwillingness to satisfy debts;” and 
“(c) a history of not meeting financial obligations.” Applicant’s history of delinquent debt 
is documented in her credit reports, SOR response, and hearing record. The Government 
established the disqualifying conditions in AG ¶¶ 19(a) and 19(c) requiring additional 
inquiry about the possible applicability of mitigating conditions. 
  
Five mitigating conditions under AG ¶ 20 are potentially applicable:  
 
(a) the behavior happened so long ago, was so infrequent, or occurred 
under such circumstances that it is unlikely to recur and does not cast doubt 
on the individual’s current reliability, trustworthiness, or good judgment;  
  
(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;2 and 
 
                                            
2The Appeal Board has previously explained what constitutes a “good faith” effort to repay overdue 
creditors or otherwise resolve debts:  
 
In order to qualify for application of [the “good faith” mitigating condition], an applicant must 
present evidence showing either a good-faith effort to repay overdue creditors or some 
other good-faith action aimed at resolving the applicant’s debts. The Directive does 
not define the term “good-faith.” However, the Board has indicated that the concept of 
good-faith “requires a showing that a person acts in a way that shows reasonableness, 
prudence, honesty, and adherence to duty or obligation.” Accordingly, an applicant must 
do more than merely show that he or she relied on a legally available option (such as 
bankruptcy) in order to claim the benefit of [the “good faith” mitigating condition]. 
 
(internal citation and footnote omitted) ISCR Case No. 02-30304 at 3 (App. Bd. Apr. 20, 2004) (quoting 
ISCR Case No. 99-9020 at 5-6 (App. Bd. June 4, 2001)).   
   
 
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(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. 
 
The Appeal Board concisely explained Applicant’s responsibility for proving the 
applicability of mitigating conditions as follows:  
 
Once a concern arises regarding an Applicant’s security clearance 
eligibility, there is a strong presumption against the grant or maintenance of 
a security clearance. See Dorfmont v. Brown, 913 F. 2d 1399, 1401 (9th 
Cir. 1990), cert. denied, 499 U.S. 905 (1991). After the Government 
presents evidence raising security concerns, the burden shifts to the 
applicant to rebut or mitigate those concerns. See Directive ¶ E3.1.15. The 
standard applicable in security clearance decisions is that articulated in 
Egan, supra. “Any doubt concerning personnel being considered for access 
to classified information will be resolved in favor of the national security.” 
Directive, Enclosure 2 ¶ 2(b).  
 
ISCR Case No. 10-04641 at 4 (App. Bd. Sept. 24, 2013).  
 
AG ¶¶ 20(a), 20(b), 20(c), and 20(d) apply. AG 20(e) does not apply. Applicant 
paid the debts in SOR ¶¶ 1.a ($21,270), 1.p ($1,742), 1.q ($1,842), and 1.v ($96). The 
debts in SOR ¶¶ 1.t ($1,864) and 1.w ($436) are duplications of other SOR debts. The 
debts in SOR ¶¶ 1.d ($546), 1.h ($442), and 1.r ($706) were removed from her credit 
reports after she challenged them.  
 
Two recent Appeal Board decisions illustrate the analysis for applying AG ¶¶ 20(a) 
and 20(b). In ISCR Case No. 09-08533, the applicant had $41,000 in delinquent credit 
card debt and defaulted on a home loan generating a $162,000 delinquent debt. Id. at 2. 
That applicant filed for bankruptcy the same month the Administrative Judge issued her 
decision. Id. at 1-2. The applicant in ISCR Case No. 09-08533 was recently divorced, had 
been unemployed for 10 months, and had childcare responsibilities. Her former husband 
was inconsistent in his child support payments to her. The Appeal Board determined that 
AG ¶ 20(a) was “clearly applicable (debt occurred under such circumstances that it is 
unlikely to recur and [the debt] does not cast doubt on the individual’s current reliability, 
trustworthiness, or good judgment)” even though that applicant’s debts were unresolved 
at the time the Administrative Judge’s decision was issued. The Appeal Board also 
decided that the record evidence raised the applicability of AG ¶ 20(b) because of the 
absence of evidence3 of irresponsible behavior, poor judgment, unreliability, or lack of 
trustworthiness. Id. at 4.   
  
                                            
3 Applicant has the burden of proving the applicability of any mitigating conditions, and the burden 
to disprove a mitigating condition never shifts to the Government. 
   
 
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Similarly, in ISCR Case No. 08-06567 at 3 (App. Bd. Oct. 29, 2009) the Appeal 
Board addressed a situation where an applicant was sporadically unemployed and lacked 
the ability to pay her creditors. The Appeal Board noted “it will be a long time at best 
before she has paid” all of her creditors. The applicant was living on unemployment 
compensation at the time of her hearing. The Appeal Board explained that such a 
circumstance was not necessarily a bar to having access to classified information stating: 
 
However, the Board has previously noted that an applicant is not required 
to be debt-free nor to develop a plan for paying off all debts immediately or 
simultaneously. All that is required is that an applicant act responsibly given 
his [or her] circumstances and develop a reasonable plan for repayment, 
accompanied by “concomitant conduct,” that is, actions which evidence a 
serious intent to effectuate the plan. See ISCR Case No. 07-06482 at 3 
(App. Bd. May 21, 2008). 
 
ISCR Case No. 08-06567 at 3 (App. Bd. Oct. 29, 2009). The applicant in ISCR Case No. 
08-06567 used his limited resources to (1) resolve some of his debts; (2) had a repayment 
plan for the remaining debts; and (3) took “reasonable actions to effectuate that plan.” Id. 
The Appeal Board remanded the Administrative Judge’s decision because it did not 
“articulate a satisfactory explanation for his conclusions,” emphasizing the Administrative 
Judge did “not explain[] what he believes that applicant could or should have done under 
the circumstances that he has not already done to rectify his poor financial condition, or 
why the approach taken by applicant was not ‘responsible’ in light of his limited 
circumstances.” Id.   
 
 Application of AG ¶ 20(c) is warranted. Applicant received financial counseling, 
and she generated a PFS and budget. Her financial situation was damaged by medical 
problems, underemployment,4 and unemployment. She acted responsibly by paying as 
many debts as possible and establishing payment plans for several debts. Although there 
is limited evidence of record that she established and maintained contact with her 
creditors,5 her financial problem is being resolved or is under control.      
 
 AG ¶ 20(d) is partially applicable. Applicant paid four SOR debts, including her 
largest debt for $21,270, which she settled for $2,000, even though that debt was 
collection barred by the statute of limitations. She admitted responsibility for and took 
reasonable and responsible actions to resolve additional debts, establishing some good 
                                            
4Applicant’s income is below the federal poverty level of $24,250 for a family of four, and she is 
eligible for various federal poverty programs, including Medicaid. See Health and Human Services website, 
https://aspe.hhs.gov/poverty-guidelines. 
  
5“Even if Applicant’s financial difficulties initially arose, in whole or in part, due to circumstances 
outside his [or her] control, the Judge could still consider whether Applicant has since acted in a reasonable 
manner when dealing with those financial difficulties.” ISCR Case No. 05-11366 at 4 n.9 (App. Bd. Jan. 12, 
2007) (citing ISCR Case No. 99-0462 at 4 (App. Bd. May 25, 2000); ISCR Case No. 99-0012 at 4 (App. Bd. 
Dec. 1, 1999); ISCR Case No. 03-13096 at 4 (App. Bd. Nov. 29, 2005)). A component is whether he or she 
maintained contact with creditors and attempted to negotiate partial payments to keep debts current. 
   
 
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faith.6 AG ¶ 20(e) is not applicable. Three SOR debts were removed from her credit 
reports after she challenged them; however, she did not provide documentation 
establishing a reasonable dispute for any of her SOR debts.    
 
Based on Applicant’s credible and sincere promise to pay her debts and her track 
record of paying her debts, future new delinquent debt “is unlikely to recur and does not 
cast doubt on [Applicant’s] current reliability, trustworthiness, or good judgment,” and 
“there are clear indications that the problem is being resolved or is under control.” Her 
payments of her debts showed good faith. I am confident that Applicant will 
conscientiously endeavor to maintain her financial responsibility. Her efforts are sufficient 
to mitigate financial considerations security concerns.  
 
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 the Applicant’s 
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.  
 
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. I have incorporated my comments under 
Guideline F in my whole-person analysis. Some of the factors in AG ¶ 2(a) were 
addressed under that guideline, but some warrant additional comment.  
                                            
6The Appeal Board has previously explained what constitutes a “good faith” effort to repay overdue 
creditors or otherwise resolve debts: 
 
In order to qualify for application of [the “good faith” mitigating condition], an applicant must 
present evidence showing either a good-faith effort to repay overdue creditors or some 
other good-faith action aimed at resolving the applicant’s debts. The Directive does not 
define the term ‘good-faith.’ However, the Board has indicated that the concept of good-
faith ‘requires a showing that a person acts in a way that shows reasonableness, prudence, 
honesty, and adherence to duty or obligation.’ Accordingly, an applicant must do more than 
merely show that he or she relied on a legally available option (such as bankruptcy) in 
order to claim the benefit of [the “good faith” mitigating condition].  
 
(internal citation and footnote omitted) ISCR Case No. 02-30304 at 3 (App. Bd. Apr. 20, 2004) (quoting 
ISCR Case No. 99-9020 at 5-6 (App. Bd. June 4, 2001)). 
   
 
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Applicant is a 31-year-old security specialist, who has worked for her employer 
since April 2014. In 2012, she received her GED diploma. She has never married, and 
her children are ages four months, six years, and 12 years. Friends, colleagues, and 
supervisors described her as honest, diligent, enthusiastic, detail oriented, trustworthy, 
responsible, reliable, and dedicated. She is serious about repairing her credit and caring 
for her family. Her character statements support her access to classified information. 
 
Applicant’s SOR alleges 23 delinquent debts totaling $37,524. She paid four SOR 
debts; two SOR debts are duplications; and three SOR debts were removed from her 
credit reports after she challenged them. She reduced the delinquent debt total by over 
75 percent to $8,568. She promised to continue her efforts at debt resolution. The Appeal 
Board has addressed a key element in the whole-person analysis in financial cases 
stating: 
  
. . . the concept of meaningful track record necessarily includes evidence of 
actual debt reduction through payment of debts. 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. 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. 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. 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.  
 
ISCR Case No. 07-06482 at 2-3 (App. Bd. May 21, 2008) (internal citations and quotation 
marks omitted). Applicant has established a “meaningful track record” of debt re-payment, 
and I am confident she will maintain her financial responsibility. 
 
I have carefully applied the law, as set forth in Egan, Exec. Or. 10865, the Directive, 
and the AGs, to the facts and circumstances in the context of the whole person. Financial 
considerations security concerns are mitigated. 
 
  
   
 
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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 through 1.w:   For Applicant 
 
Conclusion 
 
In light of all of the circumstances presented by the record in this case, it is clearly 
consistent with national security to grant or continue Applicant’s eligibility for a security 
clearance. Eligibility for access to classified information is granted. 
 
 
_________________________ 
MARK HARVEY 
Administrative Judge