1 
 
 
 
               DEPARTMENT OF DEFENSE 
     DEFENSE OFFICE OF HEARINGS AND APPEALS 
 
 
 
 
In the matter of:  ) 
 ) 
  REDACTED  )   ISCR Case No. 15-02324 
   ) 
Applicant for Security Clearance  ) 
 
 
Appearances 
 
For Government: David F. Hayes, Esq., Department Counsel 
For Applicant: Pro se 
 
 
______________ 
 
Decision 
______________ 
 
 
MATCHINSKI, Elizabeth M., Administrative Judge: 
 
A single mother, Applicant struggled financially to support herself and her young 
child. Four credit card accounts became delinquent, and 23 medical debts totaling $1,356 
were placed for collection. She defaulted on $15,768 in student loan debt. Applicant has 
been making timely payments on her student loans since 2013, and she resolved two past-
due credit card debts before they became an issue for her security clearance. She has 
begun making payments toward her remaining delinquencies. Clearance is granted. 
 
Statement of the Case 
 
 On September 23, 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 it clearly consistent with the national interest to grant or continue security 
clearance eligibility for her. The DOD CAF took the action under Executive Order (EO) 
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 
 
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Determining Eligibility for Access to Classified Information (AG) effective within the DOD on 
September 1, 2006. 
 
On November 5, 2015, Applicant answered the SOR allegations and requested a 
hearing before an administrative judge from the Defense Office of Hearings and Appeals 
(DOHA). On March 9, 2016, the case was assigned to a DOHA administrative judge to 
conduct a hearing to determine whether it is clearly consistent with the national interest to 
grant or continue a security clearance for Applicant. On April 20, 2016, the case was 
transferred to me. On May 19, 2016, I scheduled a hearing for June 14, 2016. 
 
I convened the hearing as scheduled. Four Government exhibits (GEs 1-4) were 
admitted into evidence without objection. Applicant testified, as reflected in a transcript (Tr.) 
received on June 21, 2016. 
 
I held the record open initially for two weeks after the hearing for Applicant to 
supplement the record with documentary exhibits. On June 16, 2016, Applicant submitted 
three exhibits, which were entered into the record as Applicant exhibits (AE) A-C without 
objection. On June 27, 2016, Applicant submitted five additional documents, which were 
entered into evidence as AEs D-H. The record closed on June 27, 2016, when Department 
Counsel expressed no objection to her post-hearing submissions.  
 
Findings of Fact 
 
 The SOR alleges under Guideline F that, as of September 23, 2015, Applicant owed 
credit card collection debts of $919 (SOR ¶ 1.a), $599 (SOR ¶ 1.i), and $472 (SOR ¶ 1.j); a 
charged-off credit card debt of $697 (SOR ¶ 1.b) and two other charged-off accounts (SOR 
¶¶ 1.c and 1.d, amounts not alleged); four student loans in collection totaling $17,125 
(SOR ¶¶ 1.e-1.h); and 23 unidentified medical debts in collection totaling $1,356 (SOR ¶¶ 
1.k-1.gg), 13 of which were $25 or less. When Applicant responded to the SOR, she 
denied that the lender identified in SOR ¶¶ 1.e-1.h held her student loans. She admitted 
the remaining allegations, although she added that some of the debts (SOR ¶¶ 1.l-1.o and 
1.ee) were not showing on her credit report. She indicated that she had sent letters to the 
creditors allegedly holding debts that were not student loans. 
 
 After considering the pleadings, exhibits, and transcript, I find that the debt in SOR ¶ 
1.c is duplicated in SOR ¶¶ 1.i and 1.j. Additional findings of fact follow. 
 
Applicant is a 37-year-old single mother with a 10-year-old son. She earned her 
bachelor’s degree in May 2001, and she continued to live with her mother while working as 
a receptionist in the security department for a defense contractor from January 2003 to 
November 2004. With the investigation of her background for security clearance eligibility 
still pending, Applicant was terminated for too many personal emails and telephone calls 
on the job. Apparently shortly thereafter, her clearance eligibility was adjudicated favorably. 
After a few months of unemployment, Applicant began working as an office administrator 
for a small defense contractor that was later acquired by her current employer. Her top 
secret clearance was renewed around July 2009. (GE 1; Tr. 36-37.) In 2010, she became 
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facility security officer (FSO) when the previous FSO was laid off. The change in position 
did not come with an increase in her salary until 2012, despite her added responsibilities. 
(Tr. 58-60.) As of June 2016, there was no classified material at her facility, but she 
handles security clearance matters and 75% of the employees have security clearance. 
(Tr. 40-42.)  
 
Applicant was earning $12 an hour when her son was born in 2006. (Tr. 30.) She 
struggled financially to support herself and her son without any paternal involvement or 
financial assistance from her son’s father. (Tr. 33-34.) She elected not pursue him for child 
support because he squandered an inheritance and was in and out of jail, and she did not 
want his negative influence in her son’s life. (Tr. 34, 52.) Applicant had some help with 
housing in that she continued to live with her mother until June 2014, when she moved into 
her own apartment with her son.
1
 (Tr. 52-53.) When she lived with her mother, she paid her 
mother rent of $50 to $75 per week. At times, she covered electricity and water bills for her 
mother. (Tr. 54.) Childcare for her son cost her $200 a week. Her son initially needed full-
day kindergarten so that she could work full time. Private kindergarten cost her between 
$150 and $165 per week. After her son started public school, she paid $88 a week for 
afterschool care. (Tr. 25-27.) She was paying over $200 a month on her student loans, 
which she had obtained in September 1997 for $2,625 (SOR ¶ 1.h), in September 1998 for 
$3,500 (SOR ¶ 1.g), in September 1999 for $5,500 (SOR ¶ 1.f), and in September 2000 for 
$5,500 (SOR ¶ 1.e). (GE 2; Tr. 21, 57, 70.) 
 
Applicant incurred many small medical co-payment debts for prescriptions and 
doctor visits for her son, who had a recurring medical issue that was not properly 
diagnosed or treated until January 2013. (Tr. 30-33.) Then unaware that she could arrange 
for affordable payments to her medical creditors (Tr. 20-21), Applicant allowed several 
medical debts to go to collections. (GEs 2-4.) Her annual salary in 2010 was about 
$35,000. (Tr. 66.) In 2011, she “financially hit the wall” (Tr. 34), and she turned to credit 
cards to pay for necessities for herself and her son. (Tr. 36.) She started falling behind on 
her student loans in April 2010, and she defaulted on them in January 2011. (GEs 2, 4.) 
 
To renew her security clearance eligibility, on June 11, 2014, Applicant completed 
and certified to the accuracy of a Questionnaire for National Security Positions (SF 86). 
She responded affirmatively to inquiries about any delinquencies involving routine 
accounts. She listed the debt in SOR ¶ 1.d, which had been charged off for approximately 
$300, and the debt in SOR ¶ 1.j, which she indicated was on her credit report as a 
collection debt of $472. Applicant explained that she was not sure about the debt because 
she had not received any mail or telephone calls about the debt. Applicant listed two other 
collection debts that she had paid in 2013. (GE 1.) 
 
Available credit information shows that Applicant’s student loans were in collection 
as of June 2012. (GE 2.) Recent student loan documentation shows that her present loan 
servicer is collecting on two accounts opened in April 2013 for $13,049 and in November 
2013 for $2,719. (AE B.) Applicant has had a record of timely payments since then on her 
                                                 
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Applicant testified that her mother told her that she was going to sell the house and move into an apartment, 
so Applicant had to find another place to live. (Tr. 56.) 
4 
 
student loans. However, as of June 2014, Applicant owed $919 (SOR ¶ 1.a) on a credit 
card account charged off for $751 and placed for collection. She owed $697 on a charged-
off credit card (SOR ¶ 1.b) from 2010. A $471 charged-off debt from April 2010 (SOR ¶ 
1.c) had been sold to the lender in SOR ¶ 1.i, who reported a $599 balance as of 
December 2012. However, a subsequent assignee listed the outstanding balance at $472 
as of June 2014 (SOR ¶ 1.j). Another credit card lender (SOR ¶ 1.d) had charged off 
$1,000 in March 2011. Applicant paid the debt in May 2013. (GEs 1, 2, 4; AE G.) Several 
medical debts incurred primarily between 2008 and 2011 and totaling $1,356 were in 
collection (SOR ¶¶ 1.k-1.gg). (GE 2.) Applicant was making timely payments of $297 per 
month on a car loan obtained in June 2008 for $12,449. She had a history of late payments 
on the loan, from 30 to 60 days, although she had been current in her payments since July 
2011. (GEs 2, 3.) 
 
On September 15, 2014, Applicant was interviewed by an authorized investigator for 
the Office of Personnel Management (OPM) about her delinquent debts. (Tr. 23.) The 
record before me does not include any report from that interview. At the suggestion of her 
OPM interviewer, Applicant sent letters to the creditors identified in SOR ¶¶ 1.a-1.d, 1.i-1.j, 
and to a collection entity that might be holding some of her past-due medical debts. She 
asked for verification of the debts and expressed a willingness to discuss repayment 
arrangements. The creditors did not respond. (Tr. 22-24, 38.) 
 
As of February 20, 2015, the credit card delinquencies in SOR ¶¶ 1.a and 1.b had 
not been resolved. Approximately $1,058 in medical collection debt was still on her credit 
record. The medical debts in SOR ¶ 1.l and 1.m were no longer on her credit record, 
although there is no evidence that they had been paid. Applicant was making timely 
payments on her car loan (balance $4,355) and on her student loans (balances $11,814 
and $2,555). (GE 3.) After Applicant received the SOR, she sent another inquiry to the 
creditors that had not responded to her earlier request for verification. (AE C.) She had 
received no responses as of her security clearance hearing in June 2016. (Tr. 23-24.) 
 
Applicant’s afterschool costs Increased by $20 weekly starting around September 
2015 because she began paying for before-school care as well as afterschool care for her 
son. In previous years, she went into work later but then had to make up the time at night. 
Additionally, her son had to take a bus to another location for his afterschool program, but 
his new program was at his school. (Tr. 64-65.) In November 2015, Applicant borrowed 
$587 from her mother to pay for new brakes for her car. She has since repaid the loan. (Tr. 
61-62.) 
 
Applicant’s credit report of December 16, 2015, showed 18 outstanding medical 
collection accounts totaling $842 (SOR ¶¶ 1.k, 1.p-1.dd, and 1.ff-1.gg). She owed only two 
past-due credit card accounts (SOR ¶¶ 1.a and 1.b). Applicant had recently opened $500-
limit credit card accounts in April 2015 and in July 2015 that were rated as current with 
respective balances of $490 and $395. In June 2015, she paid off her car loan with a final 
payment of $4,191. (GE 4.) Applicant obtained a loan of $8,000 from her 401(k) to pay off 
her car and camp for the full summer for her son. She saved about $750 from the 401(k) 
loan in case a creditor responded to her written inquiry about repayment arrangements. 
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Applicant is repaying the 401(k) loan at $200 monthly, less than her former car payment of 
$297 monthly. (Tr. 49-50, 56.) The 401(k) loan repayment term is five years. (Tr. 57.)  
 
Applicant was making timely monthly payments of $19 and $95 on her student loan 
balances of $2,422 and $11,094 as of December 2015. (GE 4.) Student loan payment 
documents confirm that Applicant continued to make monthly payments totaling about 
$121 a month through at least June 2016 to reduce her aggregate student loan balance to 
$12,876. (AE B; Tr. 29.) Her monthly scheduled payments increased slightly in 2016 after 
the loan servicer conducted its annual evaluation of her financial status. (Tr. 57.) 
 
At her hearing in June 2016, Applicant expressed an intention to pay her debts if 
she could find whom she needed to pay. (Tr. 39.) She estimated that she had about $500 
in discretionary monthly income because of the increase in her salary in 2016. (Tr. 39.)  
She had not considered calling her son’s medical providers about her past-due accounts 
since they had gone to collections. She assumed she had to contact the collection entities. 
(Tr. 44-45.) 
 
Applicant contacted her non-student loan creditors shortly after her security 
clearance hearing. Applicant tracked down the collection entity holding $440 of her 
delinquent medical debts, including the debt in SOR ¶ 1.k, which was for pediatric services. 
Applicant arranged to repay the debts at $110 per month for four months starting 
immediately. (AEs A, D, F.) Her first payment on June 14, 2016, paid off the medical debts 
in SOR ¶¶ 1.r, 1.u, 1.w, and 1.gg. (AE F.)  
 
The creditor collecting her delinquent credit card debt in SOR ¶ 1.a agreed to settle 
her $919 balance for $761, payable in seven monthly payments of $108. Applicant 
arranged for automatic deduction of the payments from her checking account starting on 
June 14, 2016. On June 15, 2016, the creditor confirmed receipt of her first payment. (AEs 
D, E.)  Applicant arranged to make payments of $50 a month toward the $697 credit card 
debt in SOR ¶ 1.b with her first payment to be mailed on June 16, 2016. Applicant learned 
that the creditor in SOR ¶ 1.j had acquired the charged-off debt in SOR ¶ 1.c (SOR ¶ 1.i, 
same debt),
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 and that the debt had been fully satisfied on June 27, 2014. (AEs A, D, H.) 
Applicant was able to confirm that the debt in SOR ¶ 1.d had been paid off in 2013. (AEs 
A, D, G.) 
 
With annual pay increases of 2% and a raise in 2012, Applicant’s take-home pay 
has increased over the years from $1,100 bi-weekly initially to $1,500 bi-weekly currently. 
(Tr. 28.) Her annual salary is $55,000. (Tr. 65.) As soon as her pay is deposited, she pays 
her bills online before making any other plans for her money. (Tr. 35.) She has a budget in 
place to ensure that she stays apprised of her obligations and does not become 
delinquent. (Tr. 35.) Her rent is $1,125 per month. (Tr. 46.) She has had Internet all along 
so that she could work from home when her son was ill. When her financial situation 
became more stable, she acquired cable television service. (Tr. 46-47.) Applicant pays 
                                                 
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Available documentation shows that the debt in SOR ¶ 1.c was sold after being charged off to the collection 
entity in SOR ¶ 1.i, which then transferred the debt in December 2012 to the collection entity in SOR ¶ 1.j. The 
debt was paid in June 2014. (GE 2; AE H.) 
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$120 per month combined for her cable and Internet service. (Tr. 66.) She has medical 
insurance through her employer. (Tr. 47.) 
 
Applicant has four active credit card accounts with balances that do not exceed 
$1,000 on each. She uses credit cards for necessities and car repairs. (Tr. 48-49.) 
 
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 about 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). 
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Analysis 
 
Guideline F, Financial Considerations 
 
 The security concerns about financial considerations are set forth 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. 
 
 Applicant struggled to support herself and her son. She had some help from her 
mother, who allowed her to live at home at minimal rent. Yet she had no financial support 
from her son’s father. Medical bills for her son of as little as $5 and $25 were placed for 
collections. By June 2014, she owed some $1,356 in medical collection debt. As of 
December 2015, 18 medical collection debts totaling $842 were still on her credit record. 
Applicant began falling behind on her student loans in April 2010. She made no student 
loan payments from January 2011 until 2013, commencing repayment after they had been 
placed for collection. Four credit card accounts became seriously delinquent, although she 
resolved two of them (SOR ¶¶ 1.c and 1.d) in June 2014 and in May 2013 before the SOR 
was issued. Two disqualifying conditions, AG ¶ 19(a), “inability or unwillingness to satisfy 
debts,” and AG ¶ 19(c), “a history of not meeting financial obligations,” apply. 
 
 Concerning mitigation of her delinquent debts, AG ¶ 20(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,” is established in that the delinquencies were not incurred recently. However, AG 
¶ 20(a) does not mitigate the financial burden of unresolved debt, and Applicant had not 
made any payments toward the credit card delinquencies in SOR ¶ 1.a or SOR ¶ 1.b or her 
medical collection debts as of her security clearance hearing in June 2016. 
 
 AG ¶ 20(b), “the conditions that resulted in the financial problem were largely 
beyond the person’s control (e.g., loss of employment, a business downturn, unexpected 
medical emergency, or a death, divorce or separation), and the individual acted responsibly 
under the circumstances,” applies to some extent in that she had to raise her son on her 
own without any help from her son’s father. While it was her choice not to pursue her son’s 
father for child support, she likely would have had little success in that regard since he was 
financially irresponsible (e.g., he squandered an inheritance) and he was a repeat criminal 
offender. Applicant also incurred medical expenses for her son that strained her finances. 
However, AG ¶ 20(b) does not mitigate the poor financial judgment she exhibited in 
allowing debts as little as $5 and $25 to be placed for collection. 
 
 Applicant has a credible case for mitigation under AG ¶ 20(c), “the person has 
received or is receiving counseling for the problem and/or there are clear indications that 
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the problem is being resolved or is under control,” and, to a lesser extent, AG ¶ 20(d), “the 
individual initiated a good-faith effort to repay overdue creditors or otherwise resolve 
debts.” Payments after collection do not carry as much weight in mitigation as had 
Applicant maintained contact with her creditors and attempted to obtain a hardship 
deferment of her student loans or tried to negotiate partial payments of her other debts. 
Even so, she has shown good faith in making her student loan payments on time since 
2013, when she was contacted by her current loan servicer. She satisfied two of her 
delinquent credit card accounts before the debts became an issue for her security 
clearance eligibility. 
 
 The Government raised some legitimate concerns about Applicant’s delay in 
addressing the credit card debts in SOR ¶¶ 1.a and 1.b and the many medical collection 
debts on her record. The burden of proving the applicability of any mitigating condition is on 
the Applicant, and she did not begin repaying these debts until after her hearing. However, 
Applicant did not completely disregard her debt obligations. She sent inquiry letters to her 
creditors after her OPM interview in September 2014, and she received no response. She 
apparently followed up after the SOR was issued with no success. She did not understand 
that she could make telephone inquiries to learn which collection entities were holding her 
past-due accounts. After her hearing, she acted immediately and reached out to her 
creditors. She arranged settlements for her two credit card debts and for $440 of her 
medical debt. She made the first payments required under those agreements. Her first 
medical payment of $110 satisfied the debts in SOR ¶¶ 1.r, 1.u, 1.w, and 1.gg. 
 
 As of the close of the evidentiary record, Applicant still owed $653 to fully settle the 
debt in SOR ¶ 1.a, $647 to satisfy the debt in SOR ¶ 1.b, and approximately $1,246 in 
medical collection debt. In evaluating Guideline F cases, the Appeal Board has established 
that an applicant is not required to pay off every debt in the SOR: 
 
The Board has previously noted that the concept of a meaningful track 
record necessary includes evidence of actual debt reduction through 
payment of debts. However, an applicant is not required, as a matter of law, 
to establish that [she] has paid off each and every debt listed in the SOR. All 
that is required is that an applicant demonstrated that [she] has established a 
plan to resolve [her] financial problems and taken significant actions to 
implement that plan. The Judge can reasonably consider the entirety of an 
applicant’s financial situation and evaluating the extent to which that 
applicant’s plan for the reduction of his outstanding indebtedness is credible 
and realistic. There is no requirement that the plan provide for payments on 
all outstanding debts simultaneously. Rather, a reasonable plan (and 
concomitant conduct) may provide for the payments 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. 
 
See ISCR Case No. 07-06482 at 2-3 (App. Bd. May 21, 2008) (internal citations and 
quotation marks omitted). Applicant’s record of student loan repayment augurs favorably 
for whether she can reasonably be expected to continue to make the monthly payments 
9 
 
promised to her other creditors and eventually resolve her debts. With the slight increase in 
her salary for 2016, she had about $500 in discretionary income each month, so she 
should be able to afford the $268 per month she has committed to pay. 
 
 Applicant’s financial situation is improving. She has four open credit card accounts 
with balances not exceeding $1,000 on each. While she will be repaying her 401(k) loan for 
another four years, her monthly repayment at $200 a month is less than what she had 
been paying for her car. Perhaps more importantly going forward, Applicant understands 
that she made a mistake in allowing debts to go to collections. She makes sure that her 
bills are paid on time. She has made sufficient progress to resolve the financial issues of 
security concern in her favor. 
 
Whole-Person Concept 
 
Under the whole-person concept, the administrative judge must consider the totality 
of an applicant’s conduct and all relevant circumstances in light of the nine adjudicative 
process factors in AG ¶ 2(a).
3
 The analysis under Guideline F is incorporated in my whole-
person analysis. Some of the factors in AG ¶ 2(a) were addressed under that guideline, but 
some warrant additional comment. 
 
 Applicant understandably gave priority to providing necessities for herself and her 
son. At the same time, delinquent debts raise concerns about an individual’s judgment and 
reliability with regard to being able to protect classified information. The Government must 
be able to fully rely on Applicant’s judgment. As a FSO, she has to ensure unwavering 
compliance with the rules and regulations regarding the handling and safeguarding of 
classified information by all cleared employees at her facility. 
 
 It is well settled that once a concern arises regarding an applicant’s security 
clearance eligibility, there is a strong presumption against the grant or renewal of a security 
clearance. See Dorfmont v. Brown, 913 F. 2d 1399, 1401 (9th Cir. 1990). Yet 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 the 
evidence to determine if a nexus exists between established facts and a legitimate security 
concern. Applicant is not seen as likely to jeopardize the security clearance she needs for 
her employment, which provides her an adequate income to support herself and her son. 
Her present debt burden is manageable. For the reasons noted above, I conclude that it is 
clearly consistent with the national interest to continue her security clearance eligibility. 
                                                 
3 
The factors under AG ¶ 2(a) are as follows: 
 
(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. 
 
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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-1.gg:   For Applicant 
 
Conclusion 
 
In light of all of the circumstances presented by the record in this case, it is clearly 
consistent with the national interest to continue Applicant’s eligibility for a security 
clearance. Eligibility for access to classified information is granted. 
 
 
_____________________ 
Elizabeth M. Matchinski 
Administrative Judge