DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
)         ADP Case No. 15-07064
)
)
Applicant for Public Trust Position )
Appearances
For Government: Tovah, Minster, Esq., Department Counsel
For Applicant: Pro se 
______________
Decision
______________
MASON Paul J., Administrative Judge:
Between December 2008 and December 2014, Applicant incurred close to $57,000
in debts. She attempted to conceal the indebtedness in her security questionnaire in
October 2014. Her evidence in mitigation fails to meet her ultimate burden of persuasion
under the guidelines for financial considerations and personal conduct. Eligibility for a
public trust position is denied. 
Statement of the Case
Applicant completed and signed an Electronic Questionnaire for Investigations
Processing (e-QIP) on October 10, 2014. On June 29, 2016, the Department of Defense
(DOD) issued a Statement of Reasons (SOR) detailing trustworthiness concerns under the
guidelines for financial considerations (Guideline F) and personal conduct (Guideline E).
The action was taken pursuant to Executive Order 10865, Safeguarding Classified
Information within Industry (February 20, 1960), as amended; DOD 5220.6, Defense
Industrial Personnel Security Review Program (January 2, 1992), as amended (Directive);
1
DOD Regulation 5200.2-R, Personnel Security Program (January 1987) and the
adjudicative guidelines (AG) made effective for all adjudications on June 8, 2017.1
On July 30, 2016, Applicant provided a notarized answer to the SOR. The Defense
Office of Hearings and Appeals (DOHA) issued a notice of hearing on March 22, 2017 for
a hearing on April 7, 2017. The hearing was held as scheduled. The Government’s four
exhibits (GE 1-4) and Applicant’s seven exhibits (AE A-G) were entered into evidence
without objection. On February 7, 2017, Applicant furnished six additional exhibits (AE H-M)
within the period allowed for post-hearing submissions. On April 21, 2017, Department
Counsel forwarded the exhibits to me without objection. The six exhibits were admitted in
evidence. The transcript (Tr.) was received on April 18, 2017. The record closed on April
24, 2017. 
Evidentiary Rulings
Applicant was advised that her January and May 2015 interviews (PSIs) (GE 2) with
an investigator for the Office Personnel Management (OPM) may not be admitted into
evidence because it was unauthenticated.  Applicant was also advised that she could call2
for a recess to review and make corrections to the exhibit to increase its accuracy.
Applicant’s declaration that she wanted the exhibit in evidence is interpreted as having no
objection to the admissibility of the exhibit. The exhibit was admitted as GE 2. 
Findings of Fact
The SOR alleges eight delinquent debts totaling $56,943. The first two debts are
student loans totaling more than $48,000 (about 84% of her entire debt). The third account
represents a delinquent credit card. Four accounts are for cellular phones. The last account
is a retail charge account. Applicant admitted all the accounts with explanations. 
Applicant is 40 years old and divorced. She was married from August 1999 to
August 2009. She has owned her home since 2001. She has raised her seven-year-old son
without child support from the child’s father. She received a bachelor’s of science degree
in 1999 and a bachelor’s of nursing degree in May 2005. For the last eight months, she has
been taking online courses to complete her nurse practitioner degree. Since November
2010, she has been employed as a registered nurse for a federal medical facility. She
testified she was unemployed for six months in 2009 because she was pregnant and
working for a contract agency. Her e-QIP shows uninterrupted employment since May
2004. She seeks eligibility for a trustworthiness position. (GE 1 at 10-12, 18; Tr. 54)
 This case was decided using the new guidelines which became effective on June 8, 2017. These guidelines1
superseded the former guidelines which had been in effect since September 1, 2006. My decision in this case
would be the same under either group of guidelines. 
 Applicant was interviewed by telephone on May 11, 2015 about other matters unrelated to the SOR. (GE 22
at 11) 
2
Financial Considerations
Applicant contends that some of her financial problems resulted from cosigning for
her sister-in law’s two student loans. (SOR ¶¶ 1.a, 1.b) She claimed that she cosigned the
phone account listed at SOR ¶ 1.d for her former husband and promised to pay for this
account. She claimed that the credit card account at SOR ¶ 1.c was illegally used by her
college roommate. She claimed she paid the SOR ¶ 1.e account in 2016. Regarding SOR
¶ 1.f, she claimed the creditor had the account removed from her credit report. She averred
that she paid the two cell phone accounts at SOR ¶¶ 1.g and 1.h, and the accounts were
removed from her credit report. 
Concerning the personal conduct allegation under paragraph 2, Applicant stated in
her January and May 2015 PSIs and testified that she did not know that she had delinquent
debts when she certified and signed the October 2014 e-QIP. No creditor had ever told her
she had outstanding debt and she assumed her debts were current. She testified, “I don’t
usually pull my credit [report] and also not aware those people that I co-signed, even the
small bills, cell phone, I was not aware they did not pay the final bill until I pulled my credit
[report] after I received the letter from the Government (circa June 2016) about my hearing.
That’s when I pulled my credit and - - ” She subsequently testified that she was not
accustomed to pulling her credit report, particularly when her credit was approved for
making a purchase. Then, she furnished a one-page excerpt from her credit report provided
by the three credit bureaus. The document posts her last name spelled correctly and
incorrectly. The document provides a middle initial (she has no middle initial or name), and
lists an incorrect address in another state. I note the same information appears in the
government credit reports. Both the government credit reports and Applicant’s one-page
document provide her current address. Also, Applicant’s social security number is the same
in the government credit reports and Applicant’s e-QIP. (GE 3, 4; Answer to SOR; AE G;
Tr. 50-51, 62-63, 72)
The listed debts are addressed as follows:
SOR ¶¶ 1.a, 1.b - These are two student loans totaling approximately $48,000 that
Applicant cosigned for her sister-in-law in about 2004. The accounts became delinquent
between December 2008 and January 2009. Applicant understood that by cosigning she
could ultimately be responsible for the underlying debts. She initially claimed that she paid
the $5,000 settlement amount in one payment. When pressed on whether she could
provide verification of an actual pay off document of the settlement amount of $5,000,
Applicant testified, “The settlement agreement and also I could get a letter and also it is no
longer in my - - they remove it from my credit report.” Later in her testimony, she indicated
she paid the $5,000 over a 30-day period from the date posted on the student loan
settlement documentation. In her post-hearing submission, she provided another copy of
the second page of the settlement agreement. (GE 3 at 2; AE E at 2; AE L; Tr. 41-43, 57,
68-70, 75) The loan is unresolved. 
SOR ¶ 1.c - This is a credit card account with Applicant being individually
responsible in the case of default. The account became delinquent in January 2010. When
confronted in her January and May 2015 PSIs about this debt and the others listed in the
SOR, she claimed that she had a bank account in another state, but never had credit card
accounts. In her answer to the SOR, she claimed that her college roommate misused the
3
card. The credit card company told her that she was not responsible for the store charges
and that the creditor was going to remove the account from her credit report. However, she
provided documentation showing the card was designated as a bad debt and charged off
to profit and loss. She provided additional documentation without actual account numbers
showing that an account with the same name was removed from her credit report in
December 2016. Eleven days after the hearing, she submitted a letter from her credit repair
law firm announcing that they were requesting the three credit bureaus conduct appropriate
investigations on five accounts which Applicant believes should have been removed from
her credit report. Only three of the listed accounts appear in the SOR; they are SOR ¶¶ 1.c,
1.e, and 1.f. (GE 2 at 10; AE F; AE G; AE I; AE M; Tr. 60) The credit card account is
unresolved. 
SOR ¶ 1.d - This is a cell phone account with Applicant individually responsible in
case of default. The account became delinquent in December 2014. When confronted with
the debt in her January and May 2015 PSIs, she believed the account was disputed with
the credit bureau and settled in 2008. In her answer, she claimed her husband was
supposed to pay the account but did not. She promised to pay the debt. At the hearing, she
claimed that she cosigned for her husband. One of Applicant’s post-hearing exhibits shows
that she settled the account in November 2016. (GE 3; GE 4; answer to SOR; Tr. 47) The
debt is resolved. 
SOR ¶ 1.e - This is a cell phone account that became delinquent in May 2014. In her
January and May 2015 PSIs, she claimed she paid off the account in 2010 before she
discontinued the service. She intended to remove the account from her credit report. In her
answer to the SOR, she averred that her husband was supposed to take care of the
account. She indicated she would pay the account. Though she provided documentation
in December 2016 that an account with the same name, but no other identifying
information, was removed from her credit report, in April 2017, the credit repair firm
repeated its request to have the account investigated. (GE 2 at 10-11; answer to SOR; AE
I; AE M) The account is unresolved. 
SOR ¶ 1.f - This is a retail charge account that became delinquent in December
2009. When confronted with the account in her January and May 2015 PSIs, Applicant
stated that she would either pay or dispute the debt. In her SOR answer, she claimed that
the account was closed because of unauthorized activities. The creditor was supposed to
remove the account from her credit report. As with SOR ¶ 1.f, Applicant provided
documentation showing that an account with the same name, but no other identifying
information, was removed from her credit report in December 2016. Her debt repair firm
submitted another letter in April 2017 requesting that the account be investigated. (GE 2
at 9; answer to SOR; AE I; AE M) The account is unresolved. 
SOR ¶ 1.g - This is a cell phone account that made Applicant individually liable in
case of default. The account became delinquent in January 2014. When confronted with
this delinquent account in her January and May 2015 PSIs, she claimed that she had not
received any bill notices from the creditor. She intended to pay the account if it was
determined that she was liable. In her SOR answer, she contended her deposit for the
phone contract was supposed to cover the last payment on the contract. At the hearing,
Applicant claimed the account was paid off through her debt repair firm. She had an email
that she could print. She provided a post-hearing exhibit showing that she paid the account
4
in November 2016. (GE 2 at 9; GE 4 at 8; answer to SOR; AE J; Tr. 49) The account is
resolved. 
SOR ¶ 1.h - This is an account covering cable equipment. The account became
delinquent in June 2011. In her January 2015 PSI, Applicant claimed the creditor informed
her that it had no record of the account and told her to contact the credit agency. She
submitted an online dispute and was waiting for a response. In her answer to the SOR, she
repeated her claim of returning the cable equipment to the creditor. At the hearing,
Applicant contended that the account had been paid and her debt repair firm had removed
it from her credit report. No additional documentation was submitted concerning the
outcome of her 2015 online dispute or a payoff of the account. (GE 2 at 10; answer to SOR;
Tr. 49) The account is unresolved. 
Applicant testified that her current yearly salary is $93,000. Her monthly net income
is $5,500. She was asked twice about the amount of her net monthly remainder after
expenses. Her reply was that the remainder is about $2,000. She then identified each of
her monthly expenses. Her monthly car note is $740 for a vehicle she purchased in 2015.
Her mortgage is $1,800 a month. Applicant pays an average of $115 a month for electricity;
about $150 a month for cable; $70 a month for a cell phone; $160 a month for gasoline;
$200 a month for food; at least $740 a month for school tuition and an occasional $250 fee
for her son’s aftercare; and $136 a month for car insurance. Her itemized monthly
expenses are at least $1,500 more than her $2,000 monthly remainder she claimed to have
after paying all her expenses.  Other than her collaboration with the debt repair firm since3
November 2016, she has never participated in financial counseling or debt consolidation.
She operates a small nurse staffing operation that has not generated income because she
is waiting for approval of her state license application. (AE G; Tr. 61, 63-72)
Personal Conduct 
On October 10, 2014, Applicant (age 37 at the time) signed and certified an e-Qip.
In response to section 26 (financial record delinquency involving routine accounts),
Applicant answered “no” to the following questions: whether she defaulted on any type of
loan in the last seven years, whether she had debts turned over to a collection agency in
the last seven years, and whether she had any accounts or credit cards suspended,
charged off, or cancelled in the last seven years. 
One of Applicant’s reasons for answering “no” to all the financial questions was that
she did not know that certain individuals she cosigned accounts for, defaulted on those
accounts. Those accounts include the two student loan accounts for her sister-in-law (SOR
¶¶ 1.a, 1.b). Applicant expressed words that indicated she cosigned for her former husband
for accounts identified at SOR ¶¶ 1.d and 1.e. Applicant was unaware of the other listed
debts and was not informed about any delinquent accounts when she leased her car in
2015. No creditor ever notified her that she owed delinquent debt. She never obtained a
copy of her credit report because she thought all her accounts were current. (Answer to
SOR; Tr. 65-67)
 When the individual expense total is subtracted from Applicant’s net monthly income ($5,500), the net month3
remainder is closer to $1,400. (Tr. 63-69)
5
Character Evidence
Applicant provided four character references. On November 16, 2016, reference A
indicated he has known Applicant for 15 years. She helped reference A and his wife
acclimate to the local area. Applicant is dedicated to her work and profession. In reference
A’s view, when Applicant cosigned accounts for family members, she thought the accounts
were resolved when they became delinquent. Applicant believed she had honestly
answered all questions on the security form, part of the security clearance process that
reference A became frustrated with during his 15 years of employment in the federal
government. 
Reference B indicated by letter on February 16, 2016, that her recent treatment for
pain quickly led to positive results in her medical condition. She praised Applicant’s
patience in administering the treatment. 
Reference C indicated statement dated November 17, 2016, that she is the clinic
manager of the pain clinic and Applicant’s supervisor. She has known Applicant for six
years. She is impressed with Applicant’s work ethic, strong moral character, and team
player attitude. 
On November 12, 2016, reference D stated that she has known Applicant on a
professional and personal level for 10 years. Reference D considers Applicant to be a
trustworthy person. She was supportive when reference D’s father passed away. Reference
D believes that Applicant responded honestly to the questions on the security questionnaire
and is trying to deal with her financial issues. 
Policies
When evaluating an applicant’s suitability for a public trust position, the
administrative judge must consider the adjudicative guidelines (AG) which list potentially
disqualifying conditions and mitigating conditions. These guidelines must be considered in
the context of the nine general factors known as the whole-person concept to enable the
administrative judge to consider all available, reliable information about the person, past
and present, favorable and unfavorable, in making a decision.
The protection of the public trust is the paramount consideration. AG ¶ 2(b) requires
that “[a]ny doubt concerning personnel being considered for access to [sensitive]
information will be resolved in favor of national security.” 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. . . .” An applicant has the burden of proving a mitigating condition,
and the burden of disproving it never shifts to the Government. See ISCR Case No. 02-
31154 at 5 (App. Bd. Sept. 22, 2005) The applicant has the ultimate burden of persuasion
to support her case for eligibility to a public trust position. 
6
Analysis
Financial Considerations 
The security concern for financial considerations is set forth in AG ¶ 18:
Failure 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 or
sensitive information. Financial distress can also be caused or exacerbated
by, and thus be a possible indicator of, other issues of personnel security
concern such as excessive gambling, mental health conditions, substance
misuse, or alcohol abuse or dependence. An individual who is financially
overextended is at risk of having to engage in illegal acts to generate funds.
Affluence that cannot be explained by known sources of income is also a
security concern insofar as it may result from criminal activity, including
espionage.
A person who holds a public trust position has a fiduciary responsibility with the
Government to comply with all rules and regulations associated with handling sensitive
information. She also has a duty to responsibly manage her finances by living within her
means and paying voluntarily incurred debts as they become due. Managing her finances
includes monitoring her credit issues by periodically obtaining credit reports. When she
encounters financial problems, she should seek assistance from her employer, e.g., human
resources official (HRO), a facility security officer (FSO), or an outside financial counseling
organization. 
The disqualifying conditions under AG ¶ 19 are:
(a) inability to satisfy debts; 
(b) unwillingness to satisfy debts regardless of the ability to do so; 
(c) a history of not meeting financial obligations; and
(e) consistent spending beyond one’s means or frivolous or irresponsible
spending, which may be indicative of excessive indebtedness, significant
negative cash flow, a history of failure to make payments or of non-payment,
or other negative financial indicators. 
Between December 2008 and December 2014, Applicant accumulated almost
$57,000 in delinquent debt. The credit bureau reports and Applicant’s admissions establish
AG ¶¶ 19(a), (b), and (c). The monthly expenses which Applicant identified during her
testimony show that she has a negative monthly remainder of at least $1,500 every month.
This negative monthly remainder represents evidence of a negative cash flow within the
scope of AG ¶ 19(e). 
7
The burden shifts to Applicant to mitigate the delinquent financial delinquencies. Five
mitigating conditions under AG ¶ 20 are potentially pertinent: 
(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 reliability, trustworthiness, and good judgment; 
(b) the conditions that resulted in the financial problem were largely beyond
the person's control and the individual acted responsibly under the
circumstances;
(c) the person has received or is receiving financial counseling for the
problem from a legitimate and credible source, such as a nonprofit credit
counseling service, and there are clear indications that the problem is being
resolved or is under control; 
(d) the individual initiated and is adhering to a good-faith effort to repay
overdue creditors or otherwise resolve debts; and
(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.
Applicant began to incur delinquent debt in 2008. When the SOR was published in
June 2016, she had eight debts totaling close to $57,000. Except for SOR ¶¶ 1.d and 1.g,
Applicant has not satisfied or settled the six remaining debts. She was advised that there
was some question as to whether the two student loans (SOR ¶¶ 1.a, 1.b) were settled for
$5,000 as she claimed. She indicated that she could provide additional evidence, but she
did not. When Applicant certified the e-QIP in October 2014, she was put on notice that her
debts were a government concern. She received additional notice in a more detailed
fashion when she discussed each debt in detail with an investigator from OPM in January
and May 2015. Though she supplied documentation of a settlement offer (June 2016) with
the two student loan accounts at SOR ¶¶ 1(a) and 1(b), her substantiated action to pay off
any of the listed debts did not occur until November 2016 (SOR ¶¶ 1.d, 1.g), after she
received the SOR, thereby raising ongoing security concerns about her judgment and
trustworthiness. AG ¶ 20(a) does not apply.
AG ¶ 20(b) addresses the impact of unforseen events on a person’s financial
obligations. Applicant’s divorce in 2009 and the lack of child support since 2009 entitles her
to some mitigation under the condition. However, her claim of not knowing about the debts
until she received the SOR in June 2016, is not persuasive because she discussed the
debts during the January and May 2015 PSIs. On balance, the mitigation she receives
under AG ¶ 20(b) is limited. 
Applicant has never had financial counseling. There is no evidence showing that she
received any financial counseling from the debt repair firm. Even though Applicant stated
that she paid off most of the listed debts, she only provided unequivocal documentation of
paying off SOR ¶¶ 1.d and 1.g. Other than disputing the debts, there is no evidence that
8
the debt repair firm assisted Applicant in resolving any of the accounts through payment
plans. The delinquent debts that no longer appear in her credit report probably were
removed by the statute of limitations instead of a through good-faith effort by Applicant to
resolve the debts. AG ¶ 20(c) does not apply as there are no clear indications that the
debts are under control or being resolved. AG ¶ 20(d) applies to Applicant’s resolution of
AG ¶¶ 1.d and 1.g. 
Applicant’s disputes by her debt repair firm of the five accounts listed in AE I and AE
M merit limited mitigation as the stated reasons for requested relief are too general to
substantiate the basis of the disputes. AG ¶ 20(e) warrants scant mitigation.
Personal Conduct
The security concern for personal conduct is set forth in AG ¶ 15:
Conduct involving questionable judgment, lack of candor, dishonesty, or
unwillingness to comply with rules and regulations can raise questions about
an individual’s reliability, trustworthiness and ability to protect classified
information. Of special interest is any failure to provide truthful and candid
answers during the security clearance process or any other failure to
cooperate with the security clearance process. The following will normally
result in an unfavorable national security eligibility determination, security
clearance action, or cancellation of further processing for national security
eligibility.
The disqualifying conditions under AG ¶ 16 are: 
(a) deliberate omission, concealment or falsification of relevant facts from any
personnel security questionnaire, personal history statement, or similar form
used to conduct investigations, determine employment qualifications, award
benefits or status, determine security clearance eligibility or trustworthiness,
or award fiduciary responsibilities; and 
d) credible adverse information that is not explicitly covered under any other
guideline and may not be sufficient by itself for an adverse determination, but
which, when combined with all available information supports a whole-person
assessment of questionable judgment, untrustworthiness, unreliability, lack
of candor, unwillingness to comply with rules and regulations, or other
characteristics indicating the person may not properly safeguard protected
information. This includes but is not limited to consideration of: (1)
untrustworthy or unreliable behavior to include breach of client confidentiality,
release of proprietary information, unauthorized release of sensitive
corporate or other government protected information; (2) disruptive, violent,
or other behavior in the workplace; (3) a pattern of dishonesty or rule
violations; and (4) evidence of significant misuse of government or other
employer’s time or resources. 
An applicant who is employed in a public trust position occupies a fiduciary
relationship with the Government founded on honesty and trustworthiness. When an
9
applicant demonstrates untruthfulness during the application process for a public trust
position, her lack of candor can have a negative impact on the ultimate decision regarding
her application for a public trust position. 
In October 2014, when Applicant checked the “no” answers under section 26 of her
e-QIP, she gave the Government the impression that she had no delinquent debts. She did
not disclose the delinquent accounts until she was confronted with them in January and
May 2015. Had she been 21 or 22 years old, just out of college, and trying to launch her
career, then there may have been some justification to excuse her “no” answers to every
financial question in the section. However, she was 37 years old in October 2014. She
received two college degrees. She has owned her own home since 2001. AG ¶ 16(a)
applies. 
Assuming that Applicant’s omission of financial information from her October 2014
e-QIP is not considered intentional, it represents a whole-person assessment of negligence
and poor judgment within the purview of AG ¶ 16(d). When she filled out the e-QIP, she
had been working for the Government facility for four years. She knew or should have
known her delinquent debts raised trustworthiness concerns for the Government. 
The mitigating conditions under AG ¶ 17 are: 
(a) the individual made prompt, good-faith efforts to correct the omission,
concealment, or falsification before being confronted with the facts; and 
(c) the offense was so minor, or so much time has passed, or the behavior
is so infrequent, or it happened under such unique circumstances that it is
unlikely to recur and does not cast doubt on the individual’s reliability,
trustworthiness, or good judgment.
An applicant receives mitigation under AG ¶ 17(a) when she makes a good-faith
effort to voluntarily come forward with the missing financial information before she is
confronted with that information. The condition does not apply because Applicant did not
reveal the information about the debts listed in the SOR until the OPM investigator
confronted her about them in May 2015.  
The omission of financial information by Applicant in October 2014 was not minor
because she sought to conceal almost $57,000 in debt. The surrounding circumstances of
her omission were not unique and continue to raise trustworthiness concerns about her
reliability and judgment. These concerns undermine the credibility of Applicant’s repeated
and unsupported claims of paying off most of the listed debts. AG ¶ 17(c) does not apply.
Whole-Person Concept
I have examined the evidence under the guidelines for financial considerations and
personal conduct from a common sense point of view and in the context of the whole
person. (AG ¶ 2(c)) I have also weighed the circumstances within the context of nine
variables known as the whole-person concept. In evaluating the relevance of an individual's
conduct, the administrative judge should consider the following factors:
10
AG ¶ 2(d) (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 the participation was 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.
Applicant is 40 years old and has bachelors’ degrees in science and nursing. She
is considered to be a trustworthy person who has developed a strong work ethic with stellar
team player qualities.  
However, the foregoing positive evidence is insufficient to overcome the adverse
evidence under the financial guideline. Applicant repeatedly stated that she paid off most
of the debts. The evidence does not support her claims. Satisfying debts with
documentation that shows a track record of payments represents strong evidence of a
good-faith effort to resolve debts. Evidence that shows only that debts were extinguished
because they became stale by the running of a statute of limitations (making the debts no
longer enforceable by the creditor) does not constitute a good-faith effort to repay overdue
creditors. 
Applicant’s omission of her financial information from her October 2014 e-QIP has
been fully discussed. Her claim that neither the car dealer nor any other creditor ever
informed her about her delinquent debts, does not relieve her of her obligation to manage
and monitor her financial obligations in a responsible manner. After making a
commonsense evaluation of the evidence in the context of the general factors of the whole-
person concept, I conclude that Applicant has not mitigated the trustworthiness concerns
arising from the guidelines for financial considerations and personal conduct. See AG ¶
2(a)(1) through 2(a)(9).
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
Subparagraphs 1.a-1.c, 1.e, 1.f, 1.h: Against Applicant
Subparagraphs 1.d, 1.g:         For Applicant
Paragraph 2 (Guideline E): AGAINST APPLICANT
Subparagraph 2.a: Against Applicant
11
Conclusion
In light of all of the circumstances presented by the record in this case, it is not
clearly consistent with national security to grant Applicant eligibility for a public trust
position. Eligibility for a public trust position is denied. 
Paul J. Mason
Administrative Judge
12