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               DEPARTMENT OF DEFENSE 
     DEFENSE OFFICE OF HEARINGS AND APPEALS 
 
 
 
 
In the matter of:  ) 
 ) 
  (Redacted)  )    ISCR Case No. 16-00082 
   ) 
Applicant for Security Clearance  ) 
 
 
Appearances 
 
For Government: Robert J. Kilmartin, Esq., Department Counsel 
For Applicant: Pro se 
 
 
______________ 
 
Decision 
______________ 
 
 
MATCHINSKI, Elizabeth M., Administrative Judge: 
 
Applicant became seriously delinquent on several debts because of the illnesses 
and deaths of two close family members. Her largest delinquency, a home-equity loan, was 
charged off for $22,789 and then cancelled in 2014. She is making payments under a debt 
management plan to resolve most of her remaining past-due debt, which totals less than 
$10,000. Clearance is granted.   
 
Statement of the Case 
 
 On June 8, 2016, 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 10865 (EO), 
Safeguarding Classified Information within Industry (February 20, 1960), as amended; 
DOD Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program 
(January 2, 1992), as amended (Directive); and the Adjudicative Guidelines for 
Determining Eligibility for Access to Classified Information (AG) effective within the DOD on  
September 1, 2006. 
 
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On July 11, 2016, Applicant answered the SOR allegations and requested a hearing 
before an administrative judge from the Defense Office of Hearings and Appeals (DOHA). 
On September 20, 2016, the case was assigned to me 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 September 27, 2016, I scheduled a hearing for October 19, 
2016. 
 
 I convened the hearing as scheduled. Four Government exhibits (GEs 1-4) and one 
Applicant exhibit (AE A) were admitted into evidence without objection. Applicant testified, 
as reflected in a transcript (Tr.) received on October 26, 2016. 
 
I held the record open for three weeks after the hearing for Applicant to submit 
additional documentation. On November 3, 2016, Applicant submitted AEs B through G, 
which were admitted without objection. The record closed on November 3, 2016, when 
Department Counsel expressed no objection to AEs B-G. 
 
Summary of SOR Allegations 
 
 The SOR alleges under Guideline F that, as of June 8, 2016, Applicant owed  two 
judgments from 2015 of $1,714 (SOR ¶ 1.a) and $1,531 (SOR ¶ 1.b); medical collection 
debts of $20 (SOR ¶ 1.c), $20 (SOR ¶ 1.d), and $409 (SOR ¶ 1.e); consumer credit 
collection debts of $1,715 (SOR ¶ 1.f), $711 (SOR ¶ 1.h), $1,532 (SOR ¶ 1.k) and $720 
(SOR ¶ 1.l); and charged-off debts of $1,410 (SOR ¶ 1.g), $712 (SOR ¶ 1.i), and $22,789 
(SOR ¶ 1.j). When Applicant answered the SOR allegations, she admitted all the debts but 
indicated that four of the allegations (SOR ¶¶ 1.a, 1.b, 1.f, and 1.k) pertained to the same 
debt, which was the subject of the financial judgment in SOR 1.a. Applicant attributed her 
delinquencies to her mother’s medical and subsequent burial expenses and then her 
daughter’s battle with cancer, ending in her untimely death. She indicated that she was 
working with a debt resolution company to resolve her delinquent accounts. (Answer.) 
 
Findings of Fact 
 
 After considering the pleadings, exhibits, and transcript, I find that SOR ¶¶ 1.a and 
1.f pertain to the same debt, and SOR ¶ 1.b is a duplicate listing of the debt in SOR ¶ 1.k. 
Additional findings of fact are as follows. 
 
  Applicant is a 50-year-old senior software engineer with an associate degree earned 
in June 1986. She has worked for her defense contractor employer since December 1986, 
and has been employed in the same department for the past 18 years. (GEs 1, 2; AE B.) 
Applicant has held a DOD security clearance for most of her employment, initially at the 
confidential level. She currently holds a secret clearance. (GE 1.) 
 
 Applicant and her spouse wed in May 1988. In October 1996, they had their only 
child, a daughter. They have owned their home since August 2004. (GE 1.) They obtained 
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a 30-year mortgage loan of $177,500. In June 2006, they obtained a secured line of credit 
(home-equity loan) of $23,100 (SOR ¶ 1.j). (GE 3.) 
 
 Applicant began to struggle financially in 2011, after her mother became ill. (Tr. 29.) 
In early May 2013, her mother incurred medical expenses at a local hospital that were only 
partially covered by Medicare. On May 11, 2013, Applicant’s mother was transported by 
ambulance from a hospice house to her home at a cost of $1,387, which Applicant paid in 
July 2013. (AE F.) In September 2013, Applicant paid $1,184 and $40 of her mother’s 
medical expenses from May 2013. On her mother’s death, Applicant covered some burial 
expenses, including $4,500 for her mother’s burial plot. (AE E.)  Shortly after her mother 
died, her father needed emergency surgery in early June 2013. In July 2013, Applicant 
paid $687 of his medical expenses. In September 2013, she paid another $48 of his 
medical expenses. (AE F.) 
 
 In late 2013 or early 2014, Applicant’s daughter was diagnosed with a rare form of 
cancer. (Tr. 32.) Her daughter was treated at a hospital in another state. Even with medical 
insurance coverage, Applicant and her spouse incurred approximately $10,000 in out-of-
pocket medical, lodging, and transportation costs related to their daughter’s care. (Tr. 28.) 
Applicant worked part time while dealing with her daughter’s illness. (GE 1; AE A.) Most of 
her and her spouse’s $110,012 in wage earnings for 2014 came from her spouse. (AE A.) 
 
 Applicant’s security clearance came up for renewal when she was coping with her 
daughter’s illness. On April 28, 2015, Applicant completed a Questionnaire for National 
Security Positions (SF 86) electronically, which she certified as accurate on May 5, 2015. 
Applicant responded affirmatively to inquiries concerning delinquencies involving routine 
accounts, and she stated, “Have been delinquent due to death/medical expenses of 
mother. Also due to medical expenses of daughter with cancer. Have never filed for 
bankruptcy or had home foreclosed.” Applicant listed unpaid debts of $154 (medical), $64, 
$714 (SOR ¶ 1.l), $1,532 (SOR ¶ 1.k, same debt in SOR ¶ 1.b), and $711. Applicant 
indicated that she would make payments of $50 a month starting on May 14, 2015, toward 
the debts in SOR ¶¶ 1.h, 1.k, and 1.l. (GE 1.) 
 
 As of May 23, 2015, several of Applicant’s accounts had been charged off or placed 
for collection. In September 2011, a $409 medical debt from May 2011 was placed for 
collection (SOR ¶ 1.e). In October 2013, a $20 medical debt from March 2013 was placed 
for collection (SOR ¶ 1.d). In February 2014, another $20 medical debt from March 2013 
was placed for collection (SOR ¶ 1.c). (GEs 3, 4.) After December 2013, Applicant stopped 
paying on a credit card with an electronics/home furnishings retailer that she had opened in 
February 2013. A debt of $1,531 was placed for collection (SOR ¶ 1.k) in November 2014. 
(GE 3.) In October 2015, the collection entity was awarded a judgment against Applicant 
(SOR ¶ 1.b). (GE 4.) In January 2015, a credit card debt of $1,714 (SOR ¶ 1.f) was placed 
for collection after six months of no payments. (GE 3.) In December 2015, the collection 
entity obtained a judgment against Applicant (SOR ¶ 1.a). (GE 4.)  
 
 Additionally, Applicant’s account with a mail order company was charged off for 
$1,410 in May 2015 (SOR ¶ 1.g). It was past due $492 and had been inactive since 
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November 2014. In August 2014, another mail order company charged off a $711 balance 
(SOR ¶ 1.h). Her account was past due $280 with no payments since February 2014. A 
credit card account, on which Applicant was an authorized user, was charged off for $712 
in June 2014 after no activity for six months (SOR ¶ 1.i). In November 2014, a $720 debt 
was placed for collection by a music/arts center (SOR ¶ 1.l). (GE 3.) 
 
 Applicant and her spouse had a history of late payments on the home-equity loan 
that they opened in June 2006 for $23,100. They failed to make their $89 monthly payment 
after December 2013, and in June 2014, their lender charged off a balance of $22,789 
(SOR ¶ 1.j). (GE 3.) The lender issued a Cancellation of Debt Form 1099-C, and Applicant 
and her spouse reported $22,790 as cancelled debt on their income tax returns for 2014. 
(AE A; Tr. 19.) 
 
 Applicant and her spouse were late making their $1,609 monthly mortgage payment 
from May 2014 through January 2015. They brought their mortgage loan current through 
June 2015. (GEs 3, 4.) For the most part, they made timely monthly payments of $289 on a 
$15,695 car loan obtained in July 2009 and of $197 on a $7,918 car loan obtained in May 
2012. As of April 2015, they owed $1,179 and $3,203 on the car loans. (GE 3.)  
  
 On June 25, 2015, Applicant was interviewed by an authorized investigator for the 
Office of Personnel Management (OPM). She indicated that she began making $50 
monthly payments toward the debts in SOR ¶¶ 1.k and 1.l and toward the $711 debt listed 
on her SF 86, which she believed was a medical collection debt. She was then confronted 
with the other adverse entries on her credit record. She did not recognize the $1,410 debt 
(SOR ¶ 1.g), the $712 debt (SOR ¶ 1.i), or the medical collection debts in SOR ¶¶ 1.c-1.e. 
She acknowledged that she had an account with the creditor in SOR ¶ 1.h, and promised 
that she would look into that debt. She speculated that the $1,714 debt (SOR ¶¶ 1.a and 
1.f, same debt) might be a credit card. As for the home-equity loan (SOR ¶ 1.j), Applicant 
stated that she called the lender about possibly lowering their payments and was told not to 
pay because all loans were being reviewed. She expressed an intention to make no 
payments on the debt because it had been charged off. Applicant had received no credit 
counseling, but her financial situation was improving. (GE 2.) 
 
 In January 2016, Applicant’s daughter lost her battle with cancer. Applicant and her 
spouse incurred funeral expenses, including $4,500 for a burial plot. (AE E; Tr. 29.) As of 
May 3, 2016, Equifax was still reporting, both as an unpaid judgment and as a collection 
debt, the debt in SOR ¶ 1.a. The judgment in SOR ¶ 1.b was separately listed as an 
outstanding debt of $1,531. The three medical collection debts in SOR ¶¶ 1.c-1.e were 
reported as unpaid. As for revolving charge delinquencies, the $1,410 (SOR ¶ 1.g) and 
$711 (SOR ¶ 1.h) debts were still on her credit record as unpaid debts. Applicant and her 
spouse had fallen behind 30 days in paying their mortgage in July and August 2015. Their 
loan was rated as current in September 2015, but they again fell behind from October 
through December 2015. In March 2016, they paid $3,218 on their mortgage loan. They 
were paying toward the arrearage on a nine-month plan with their mortgage lender. (GE 4; 
Tr. 34-35.) 
 
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 Applicant and her spouse fell behind on their mortgage loan payments because of 
medical bills and car expenses. After Applicant spent $1,400 on car repairs for her vehicle, 
it continued to have problems, so she traded in the vehicle and bought a new car for 
$15,000 cash, using the proceeds from her daughter’s life insurance policy. Her spouse 
also had to replace his vehicle. He purchased “a cheap clunker” for $1,200 so that he could 
commute to work. (Tr. 34-36.)   
 
 In early June 2016, Applicant contacted a financial resource through her employer 
and was referred to a debt resolution company. (Tr. 27.) On June 29, 2016, Applicant 
enrolled in a debt management program to repay the consumer credit debts in SOR ¶ 1.a 
($1,714, duplicated in SOR ¶ 1.f), ¶ 1.g ($1,410), ¶ 1.h ($711), ¶ 1.i ($712), and ¶ 1.l 
($798).1 Applicant reported household monthly discretionary income of $293. She 
contracted to pay an initial deposit of $120 by July 21, 2016, followed by monthly payments 
of $110 through December 2020, inclusive of a monthly service fee of $10. (AE C.) As of 
the close of the evidentiary record, Applicant had made the initial deposit and three 
payments under the debt management plan, and the debt resolution company had made 
some disbursements on the enrolled debts. (AEs B, D.) She plans to make extra payments 
with future income tax refunds or when she has additional discretionary income. (AE B.) As 
of late September 2016, the debt resolution company was looking to increase her monthly 
payment under the debt management plan to $150 a month. (Tr. 27.) 
 
 Applicant testified to her belief, apparently based on inquiry by the debt resolution 
firm on her behalf, that the creditor in SOR ¶ 1.k originally held the debt in SOR ¶ 1.f, and 
that the judgment awarded the collection entity in October 2015 (SOR ¶ 1.b) is the same 
debt as the judgment in December 2015 (SOR ¶ 1.a). (Tr. 21-23.) She continues to 
maintain that SOR ¶¶ 1.b, 1.f, and 1.k are all duplications of the judgment debt in SOR ¶ 
1.a. (AE B.) However, her May 2015 credit report (GE 3) shows that she opened a credit 
card account with an electronics/home furnishing retailer in February 2013 with a high 
credit of $1,531 as alleged in SOR ¶ 1.k. She opened a VISA card account with a bank in 
March 2013 with a high credit of $1,714, as alleged in SOR ¶ 1.f. Not only do the original 
creditors differ, but the credit limits and high credit amounts are not the same. The award 
of separate judgments with different case numbers (GE 4) and the account information on 
the credit report tend to indicate that she owed two debts of $1,531 and $1,714. The 
collection entity was reporting only the latter debt on her credit record as of April 2016. (GE 
4.) Even so, the evidence does not conclusively establish that the judgments in SOR ¶¶ 1.a 
and 1.b pertain to the same debt. 
 
Character References 
 
 Applicant’s co-workers, some of whom have been co-workers for over 15 years, 
attest to her personal integrity. She has been honest, reliable, and professional on the job. 
Applicant remained attentive to her work duties without complaint while dealing with the 
illness and death of her daughter. Well respected, Applicant has not given her co-workers 
reason to consider her a security risk. Applicant is known for being selfless and for helping 
                                                 
1 The initial contract for signature was sent to Applicant and her spouse, but all subsequent correspondence is 
addressed solely to Applicant. (AE D.)  
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those in need. She has organized fundraisers for cancer organizations, veterans, the 
military, and has knitted baby blankets and caps for ill infants. In addition to regularly 
organizing community outreach projects, she organizes her team’s social functions. (AE G.) 
 
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 EO 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 began to struggle financially because of medical and subsequent burial 
costs for her mother, who died in 2013. Then, in late 2013 or early 2014, her only child was 
diagnosed with a rare form of cancer. Applicant and her spouse stopped paying on their 
home-equity loan and on some consumer credit accounts over the next year. Their home-
equity loan was charged off for $22,789 in June 2014. While their lender forgave their debt 
by issuing a 1099-C form for the entire amount in 2014, cancellation of debt for tax 
purposes does not necessarily render the debt legally unenforceable. Even if debts have 
been forgiven or paid, the administrative judge can consider the underlying circumstances 
in deciding whether an applicant possesses the judgment and reliability that is expected of 
persons with access to classified information. See ISCR Case No. 15-04560 at 3 (App. Bd. 
Oct. 21, 2016) (citing ISCR Case No. 14-02394 at 3-4 (App. Bd. Aug. 17, 2015)). 
Moreover, Applicant owed $6,080 in delinquent consumer credit balances and $449 in 
medical collection debt as of May 2015. Another $712 (SOR ¶ 1.i) was reportedly 
delinquent, but as an authorized user, Applicant is not legally liable for repayment on that 
debt. A collection entity holding $3,245 of her past-due debt obtained financial judgments 
against her. As of May 2016, Applicant had made no progress toward resolving the debts. 
Applicant’s history of delinquency raises security concerns under AG ¶ 19(a), “inability or 
unwillingness to satisfy debts,” and AG ¶ 19(c), “a history of not meeting financial 
obligations.” 
 
 Mitigating condition 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,” has 
minimal applicability. While the $409 medical collection debt from 2011 may have been 
overlooked, most of her delinquencies were incurred within the last three years. They are 
too recent to establish AG ¶ 20(a). 
 
  Applicant has a credible case for mitigation under 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. Her record of 
delinquency is largely attributable to unforeseen medical and burial expenses for her 
mother and her daughter that took priority. Applicant incurred $10,000 in expenses related 
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to her daughter’s care and also funeral costs. In addition to incurring these unfortunate, 
nondiscretionary expenses, Applicant was understandably not focused on addressing the 
past-due debts while her daughter was battling a serious illness. 
 
 AG ¶ 20(b) requires that an individual act responsibly to address financial issues 
once the crisis has passed. In that regard, Applicant certainly could have done more to 
investigate and pay the $20 medical collection debts. The two debts were still on her credit 
record as unpaid as of May 2016. Applicant and her spouse had some unexpected vehicle 
costs of $2,600 around that time, but she should have been able to pay $40 to remove 
those debts from her credit record. Applicant acted responsibly under AG ¶ 20(b) by 
enrolling in a debt management plan to address five past-due accounts totaling $5,346, 
including $712 on the account on which she was an authorized user, and the $1,714 
subject to a court judgment (SOR ¶ 1.a).  The $1,531 debt in SOR ¶ 1.b was not included, 
apparently based on a belief that the debt is an earlier balance of the $1,714 judgment and 
not a separate debt. The $1,531 debt remains on her credit record as an unpaid judgment 
from October 2015. The Appeal Board has held that adverse information from a credit 
record is normally sufficient to meet the substantial evidence standard to establish a debt. 
See, e.g., ISCR Case No. 14-03612 (App. Bd. Aug. 25, 2015). Applicant presented no 
documentation proving that the judgments in SOR ¶¶ 1.a and 1.b pertain to a single debt.  
Applicant did not completely disregard the home-equity loan in SOR ¶ 1.j in that she 
contacted the lender about possibly reducing the monthly payment. Applicant told an OPM 
investigator that she was told to stop her payments pending creditor review of the loan. 
Assuming such advice, responsible behavior would require ongoing contact with the lender 
toward rehabilitating the loan, which would have become delinquent because of 
nonpayment. Reporting cancelled debt as income on one’s income tax return falls short of 
satisfying AG ¶ 20(b). 
 
 Applicant’s enrollment in the debt management plan to address the debts in SOR ¶¶ 
1.a, 1.g-1.i, and 1.l partially implicate AG ¶ 20(c) and AG ¶ 20(d), which provide: 
 
(c) the person has received or is receiving counseling of the problem and/or 
there are clear indications that the problem is being resolved or is under 
control; and 
 
(d) the individual initiated a good-faith effort to repay overdue creditors or 
otherwise resolve debts. 
 
Neither AG ¶ 20(c) nor AG ¶ 20(d) apply to the charged-off $22,789 home-equity loan. 
Debt write-off and cancellation are not a substitute for a track record of timely payments. 
Furthermore, there is no clear evidence of any repayment arrangements for the judgment 
in SOR ¶ 1.b. 
 
 As of the close of the evidentiary record, Applicant had made only four payments to 
the debt resolution company under her debt repayment plan. In evaluating Guideline F 
cases, the Appeal Board has established that an applicant is not required to pay off every 
debt in the SOR: 
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The Board has previously noted that the concept of a 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 [she] has paid off each and every debt listed in the SOR. All 
that is required is that an applicant demonstrate 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 [her] 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). I am confident that Applicant will continue to make the payments 
under the debt management plan, provided she has the income to do so. She and her 
spouse reported $293 in monthly discretionary income, which is enough to cover her 
contractual commitment at its present $110 monthly or the $150 monthly that was being 
contemplated as of her hearing. Given the debt forgiveness through cancellation, Applicant 
will not likely be pursued for the home-equity loan (SOR ¶ 1.j). She may owe more than 
$1,531 on the judgment in SOR ¶ 1.b if interest is continuing to accrue, but she is also not 
likely to jeopardize her longtime employment by engaging in any illegal activities to obtain 
funds to address that debt.  
 
Whole-Person Concept 
 
In the whole-person evaluation, the administrative judge must consider an 
applicant’s conduct and all relevant circumstances in light of the nine adjudicative process 
factors in AG ¶ 2(a).2 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 is a longtime defense contractor employee, who has earned the respect of 
her co-workers for her dedication, reliability, and trustworthiness. In reviewing her finances 
as a whole, she had no history of late payments before her finances were strained because 
                                                 
2 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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of the illnesses and then deaths of her mother and daughter. Her debt repayment plan had 
only been established for four months as of her hearing in October 2016. However, her 
reputation for ethical behavior among her co-workers augurs favorably with respect to 
whether she can be counted on to make the payments required under the plan. She 
managed to continue to fulfill her work duties responsibly while she was experiencing some 
very difficult family circumstances. For the reasons noted, I conclude that it is clearly 
consistent with the national interest to continue Applicant’s security clearance eligibility.  
 
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.l:  For Applicant 
 
Conclusion 
 
In light of all of the circumstances presented, it is clearly consistent with the national 
interest to grant or continue Applicant’s eligibility for a security clearance. Eligibility for 
access to classified information is granted. 
 
 
___________________ 
Elizabeth M. Matchinski 
Administrative Judge