1 
    DEPARTMENT OF DEFENSE 
     DEFENSE OFFICE OF HEARINGS AND APPEALS 
In the matter of:  ) 
 ) 
 ) ISCR Case No. 17-03570 
 ) 
Applicant for Security Clearance  ) 
Appearances 
For Government: Andre M. Gregorian, Esq., Department Counsel 
For Applicant: Thomas Albin, Esq. 
______________ 
Decision 
______________ 
MATCHINSKI, Elizabeth M., Administrative Judge: 
Applicant defaulted on a $43,990 private student loan obtained for college because 
of lack of income for herself and her parents, who had promised to assist her in repayment. 
She is making timely monthly payments on her other student loans and other debts, and is 
willing to repay the delinquent loan, but the creditor is not willing to accept what she can 
afford. The debt is not likely to be a source of pressure for Applicant, given it has been 
written off by the creditor. Clearance is granted. 
Statement of the Case 
On November 14, 2017, the Department of Defense Consolidated Adjudications 
Facility (DOD CAF) issued a Statement of Reasons (SOR) to Applicant, detailing a security 
concern under Guideline F, financial considerations. The SOR explained why the DOD 
CAF 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 National Security Adjudicative 
08/23/2018
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Guidelines for Determining Eligibility for Access to Classified Information or Eligibility to 
Hold a Sensitive Position (AG) effective within the DOD on June 8, 2017. 
 
On December 1, 2017, Applicant responded to the SOR and requested a hearing 
before an administrative judge from the Defense Office of Hearings and Appeals (DOHA). 
On February 9, 2018, 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 February 27, 2018, I scheduled a hearing for March 21, 2018. 
 
At the hearing, which I convened as scheduled, five Government exhibits (GEs 1-5) 
and four Applicant exhibits (AEs A-D) were admitted in evidence. A January 3, 2018 letter 
forwarding a copy of the GEs to Applicant and a list of the GEs were marked as hearing 
exhibits (HEs) I and II but not admitted as evidentiary exhibits. Applicant and her father 
testified, as reflected in a transcript (Tr.) received on March 30, 2018. 
 
Findings of Fact 
 
 The SOR alleges under Guideline F that, as of November 14, 2017, Applicant owed 
a single, charged-off debt for $68,240 (SOR ¶ 1.a). When Applicant answered the SOR, 
she admitted the debt without explanation. After considering the pleadings, exhibits, and 
transcript, I make the following findings of fact. 
 
Applicant is 25 years old and unmarried. She is the second of six children born to 
immigrant parents. (GE 1; Tr. 43-44, 80.) Two of Applicant’s sisters (both younger) were in 
college as of March 2018. (Tr. 44, 87.) Applicant has been cohabiting with her boyfriend in 
his apartment since July 2016. (GE 5; Tr. 17-18, 51.) 
 
Applicant has worked for a defense contractor since June 2016. She started as a 
learner in her trade and quickly progressed through six steps. With the approval of 
management, she was selected for a leadership position in her group and has added 
responsibilities in that regard. In 2018, she was promoted to a draftsman position. As of 
March 2018, Applicant was working 45 to 50 hours per week and sometimes 55 hours per 
week. Applicant held a company-issued clearance that was withdrawn on issuance of the 
SOR. Because Applicant is a valued employee, her supervisor found work for her that 
currently does not require a security clearance. (Tr. 19-23.) 
 
 Applicant graduated from high school in 2010. (Tr. 30, 50.) In August 2010, she 
matriculated in a private university at a cost of approximately $44,000 annually, inclusive of 
room and board and books. Applicant obtained a private student loan for $43,990 (SOR ¶ 
1.a) to pay for her first year of college. She was contractually liable on the loan but signed 
with the understanding from her parents that they would repay most of the loan for her.1 
(GE 2; Tr. 30-31, 43, 46, 58.) Applicant’s father testified that he and his spouse expected to 
help their daughter repay the loan. He had worked in construction part time while being 
                                                 
1 Applicant indicated during her May 18, 2017 subject interview that her father had co-signed on the loan. (GE 
5.) Her father testified that he co-signed for the loan. (Tr. 93.) Available credit information indicates that the 
account was opened individually. (GE 3.) 
3 
 
employed as a police officer for many years. After he retired from the police force in 2006, 
he began working in construction full time. (Tr. 81.) His income from the construction 
business fluctuated. He earned $400,000 annually in 2007 and 2009 and $200,000 in 
2012. He did not anticipate there would be a problem helping Applicant financially. (Tr. 94-
97.) 
 
 To reduce her college expenses, Applicant transferred to her state university at the 
start of her sophomore year.2 She lived on campus, but the move still saved her 
approximately $20,000 a year. (Tr. 32-33, 47-48.) Applicant obtained federal student loans 
for college starting in August 2011 that totaled $24,501. For her junior year, she and her 
father jointly obtained a private student loan for $14,062 from lender X in October 2012. 
(GE 3.) A Dean’s List student at the university, Applicant was forced to withdraw from 
college in December 2013 when her application for a student loan for her final semester 
was denied. Applicant’s father was to be a co-signer on that loan, but his construction 
business was not doing very well. (Tr. 33-35, 56-58.) Applicant’s father testified that his 
then business partner in 2012 embezzled approximately $650,000 from the business and 
took off for parts unknown. (Tr. 88.) Applicant’s father was left holding the notes on several 
properties owned jointly by him and his former business partner. (Tr. 89, 98.) He sold one 
of the properties at a loss, but has continued to incur expenses (insurance, mortgage 
payments, taxes, maintenance) for other properties.3 (Tr. 90.) After he paid off debts and 
expenses for the properties, he cleared about $20,000 to $30,000 in income. (Tr. 91.) It 
has been a financial struggle since then, even with his police retirement pay of $49,250 
annually. (Tr. 94-96.) 
 
 Applicant had a part-time job at a fast-food restaurant since June 2008, but her 
income was not enough to cover the costs of college. (GEs 1, 5.) After she left college, in 
addition to her student loan debts, Applicant owed $6,200 to the university in unpaid tuition 
and other expenses. (GEs 1, 5.) Applicant lived at home with her parents and siblings. She 
worked as many hours as she could at the fast-food restaurant. She became a full-time 
employee during her last year on the job. (Tr. 52.) She held a second part-time job at night 
with a competitor from January 2015 to May 2015. In August 2015, she moved into her 
own apartment and obtained a car loan of $16,326 for a 2011 model-year vehicle. (GEs 1, 
3, 5; Tr. 61.) 
 
 Applicant’s $6,200 debt with the university was placed for collection in the summer 
of 2014. In response to a collection letter, Applicant paid $100 a month toward the debt by 
automatic deduction from her bank account. After about a year, her debt was transferred to 
another collection entity. Applicant failed to notice that the withdrawals for the debt had 
ceased. In February 2016, she received a notice for collection of the $4,700 balance. She 
                                                 
2 Applicant had applied to the university while she was finishing high school, but she was not accepted. (Tr. 59-
60.) 
 
3 Applicant’s father testified that he still has income property purchased by the business consisting of a six-
family home, a single-family house, a duplex, and 42 acres of undeveloped land. He managed to sell a 
property at a loss, but he lost another to foreclosure. (Tr. 101-102.) 
4 
 
made a lump-sum payment to fully satisfy the debt in February 2016 with funds provided by 
her parents. (GEs 1, 5.) 
 
 When her student loan that she obtained at age 18 for her freshman year of college 
(SOR ¶ 1.a) came out of deferment, Applicant was required to pay $741 a month, which 
she could not afford on her income of $13.50 an hour from the fast-food restaurant. (Tr. 
51.) Applicant’s account was closed in February 2015 and placed for collection. She made 
a $300 payment in April 2015,4 but while her payment was accepted, she was told that her 
monthly obligation had increased to $790. As of February 2016, she owed a charged-off 
balance of $68,240. The creditor wrote off the balance to profit and loss.5 (GE 5; Tr. 38.) 
Her other private student loan came out of deferment in July 2014 and has not been 
delinquent. Applicant recalls making payments toward that loan in 2015. (Tr. 33.) As of July 
2017, her monthly payment was approximately $212 on a balance of $11,804. (GE 3.) Her 
consolidated federal student loan balance of $23,772 was reportedly in deferment as of 
March 2016. (GE 2.) The balance of her consolidated federal student loans was $24,925 
as of June 2017. (GE 3.) 
 
 Applicant completed and certified to the accuracy of a Questionnaire for National 
Security Positions (SF 86) on March 21, 2016. She listed two routine delinquencies, 
consisting of her debt with the university, which she paid off in February 2016, and the 
charged-off private student loan alleged in the SOR. She explained that her student loan 
had been recently charged off because she could not afford the $790 monthly payments 
demanded by the creditor. (GE 1.) In early June 2016, Applicant left her position as an 
assistant manager for the fast-food restaurant to work for her current employer, a defense 
contractor, at $15 an hour. (Tr. 52, 78.) 
 
 On May 18, 2017, Applicant was interviewed by an authorized investigator for the 
Office of Personnel Management (OPM). Applicant indicated that she had made only one 
$300 payment on a student loan that had been charged off. She made no further payments 
because the creditor was not willing to accept a smaller monthly payment that she could 
afford. Applicant added that she had obtained her credit report in March 2016, which 
showed the account as charged off and closed. She assumed that she no longer had to 
pay the debt. She had not been contacted about the debt in over a year. Applicant 
expressed her intention to follow up with the lender to ensure that she no longer owes on 
the account. If she discovers she is still responsible for repayment, she is willing to make 
$200 to $300 monthly payments until it is satisfied in full. She indicated that she is able to 
pay her other bills on her income from her defense-contractor employment. She did not 
intend to fall behind on any accounts in the future or to borrow more money than she can 
afford to repay. Applicant presented extracts from an updated credit report showing that 
                                                 
4 Applicant speculated that she may have paid the $300 in October 2014. (Tr. 66.) Available credit information 
shows a date of last payment in April 2015. (GE 5.) 
 
5 As of May 2017, TransUnion was reporting a date of February 28, 2015, for closure of her account and a last 
payment on the account of April 17, 2015. Equifax was reporting the debt as in collection/charge off as of 
February 2015. (GE 5.) The debt was reported in collection for $68,240 as of March 2016, but also as a 
charge off. (GE 2.) 
5 
 
she was making timely payments of $335 per month on her car loan and $212 on her 
private student loan with lender X. (GE 5.) 
 
 Applicant is paying her car loan, her consolidated federal student loans, and her 
student loan with lender X on time. Her federal student loans (subsidized and 
unsubsidized) have been in a debt relief program since 2016 where her repayment is 
based on her income. She is currently paying $251 per month toward her federal student-
loan debt and approximately $212 per month toward her private student loan with lender X. 
(AE C; Tr. 35-37, 50, 71.)  
 
 In October or November 2017, Applicant contacted the creditor in SOR ¶ 1.a to 
possibly arrange for repayment of her charged-off student loan. (Tr. 66-67.) She was given 
three options to repay the balance: $1,100 a month until fully satisfied; five years of equal 
monthly payments toward a reduced settlement of $64,000; or $680 a month for the first 
three months and then equal monthly payments toward the remaining balance over the 
next 4.75 years. Applicant informed the creditor that she could not afford the payments, but 
that she could pay $200 a month until her other student loans and car payment are 
satisfied. The creditor refused her counteroffer. (Tr. 40-41; Tr. 66.) Applicant did not 
consider sending any money to the creditor at that time because she “didn’t think it would 
do anything.” (Tr. 62.) In early March 2018, Applicant sent the creditor a $200 payment that 
has not been cashed. The SOR was a factor in her deciding to send the payment. (Tr. 63.) 
She has not received a 1099-C Cancellation of Debt form from the creditor, but interest is 
no longer accruing on the debt. (GE 4; Tr. 41-42, 68.) If the creditor accepts the payment, 
she intends to continue repayment at $200 a month. (Tr. 42.) When her vehicle loan is paid 
off in 2021, she will increase her payment on the defaulted student loan by $335 (the 
amount of her car payment). In 2023, her private student loan with lender X will be paid off, 
so she can put another $215 each month toward the defaulted student loan. (Tr. 49.) 
  
 Applicant’s cohabitant boyfriend is a registered nurse. He is on the lease for their 
apartment and pays the rent of $800 a month. (Tr. 29, 50, 70.) Applicant pays the 
electricity, cable, and telephone bills, which totaled approximately $413 a month as of 
March 2018. (AE A; Tr. 29.) Her base hourly wage is now $19.69. (AE B; Tr. 25.) After 
paying her expenses and her student loans, including the $200 toward the defaulted 
student loan, she is left with $38 in net discretionary monthly income based on a 40-hour 
work week. However, because of her routine overtime averaging 45 to 55 hours a week, 
she nets about $560 a month. She was paid a $500 bonus in January 2018.  (AE A.) She 
has approximately $1,000 in combined checking and savings deposits. (Tr. 69.) She has 
had no financial counseling. (Tr. 70-71.)  
 
 Applicant is only two classes short of earning her bachelor’s degree. She plans to 
complete her degree when she can afford to return to school. (Tr. 35, 54.) 
 
 Applicant’s father cannot presently provide her any financial assistance. After his 
former partner’s embezzlement, his spouse reorganized the articles and made herself 98% 
owner of the business. (Tr. 91.) In the fall of 2017, his spouse abandoned their marriage. 
6 
 
Applicant’s father still has three children living at home. He is currently helping his two 
daughters in college with their educational expenses. (Tr. 103-104.) 
 
 Applicant’s supervisor described Applicant as a highly reliable and exceptional 
worker. For her excellent performance, she was submitted for two non-automatic 
progressions in pay and approved as a working leader or “tutor.” As a “tutor,” Applicant acts 
as a resource helping with training, mentoring, process improvement, and production 
support. In her supervisor’s opinion, Applicant “continues to grow and improve at an 
exponential rate.” (AE D.) 
 
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(a), 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 national security 
eligibility will be resolved in favor of the 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 
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provides that decisions shall be “in terms of the national interest and shall in no sense be a 
determination as to the loyalty of the applicant concerned.” See also EO 12968, Section 
3.1(b) (listing multiple prerequisites for access to classified or sensitive information). 
 
Analysis 
 
Guideline F: Financial Considerations 
 
 The security concerns about financial considerations are articulated 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 can 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 greater risk of having to engage in illegal or otherwise 
questionable acts to generate funds. . . . 
 
 An applicant is not required to be debt free, but is required to manage her finances 
in a way as to exhibit sound judgment and responsibility. The concern under Guideline F is 
broader than the possibility that an individual might knowingly compromise classified 
information in order to raise money. It encompasses concerns about an individual’s self-
control, judgment, and other qualities essential to protecting classified information. 
 
 Applicant defaulted on a private student loan that she obtained for $43,990 in July 
2010. She could not afford to make the $741 monthly payments required when her loan 
came out of deferment in 2014 on her then hourly wage of $13.50, and her loan was 
charged off for $68,240. Disqualifying conditions AG ¶ 19(a), “inability to satisfy debts,” and 
AG ¶ 19(c), “a history of not meeting financial obligations,” are established. The 
Government’s case for application of AG ¶ 19(b), “unwillingness to satisfy debts regardless 
of the ability to do so,” is not persuasive. Applicant testified credibly to her willingness to 
make $200 monthly payments toward the debt. Although the creditor is demanding $790 
monthly payments, Applicant sent a $200 payment in early March 2018 to show her good 
faith. 
 
The burden is on Applicant to mitigate the negative implications for her financial 
judgment raised by her student loan default. Application of the aforesaid disqualifying 
conditions triggers consideration of the potentially mitigating conditions under AG ¶ 20. 
Four of the seven mitigating conditions warrant some consideration and could potentially 
apply in whole or in part. They are: 
 
8 
 
(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, a death, divorce or separation, clear 
victimization by predatory lending practices, or identity theft), and the 
individual acted responsibly under the circumstances; 
 
(c) the person has received or is receiving counseling for the problem from a 
legitimate and credible source, such as a non-profit credit counseling service, 
and there are clear indications that the problem is being resolved or is under 
control; and 
 
(d) the individual initiated and is adhering to a good-faith effort to repay 
overdue creditors or otherwise resolve debts. 
 
 AG ¶ 20(a) applies in that the financial behavior of concern is “so infrequent.”  Her 
default of a single student loan, albeit her largest loan, appears aberrational and not 
characteristic of her handling of her financial obligations generally. Applicant does not have 
a history of serious delinquency on credit cards, car loans, utilities, rent, or other living 
expenses. Moreover, the student loan was obtained when she was only 18 years old to pay 
for her first year of college with a reasonable expectation that her parents would assist her 
in repaying the loan. The circumstances are not likely to recur, given that Applicant has no 
intention of returning to school to finish her degree before she can afford to cover the cost. 
Even so, the mitigating impact of AG ¶ 20(a) is undermined somewhat because of her lack 
of progress toward resolving the debt. She made only one payment toward the debt, of 
$300 in April 2015, while her account was in collections. Since then, she attempted a 
payment of $200 in early March 2018, but it was unclear as of the close of the record 
whether it was accepted. Furthermore, a debt that became delinquent several years ago is 
still considered recent because “an applicant’s ongoing, unpaid debts evidence a 
continuing course of conduct and, therefore, can be viewed as recent for purposes of the 
Guideline F mitigating conditions.” ISCR Case No. 15-06532 at 3 (App. Bd. Feb. 16, 2017) 
(citing ISCR Case No. 15-01690 at 2 (App. Bd. Sept. 13, 2016)). 
 
 Applicant obtained the student loan at age 18 knowing that she would be legally 
liable for repayment at some future date. Even so, she reasonably relied on assurances 
from her parents that they would assist her in repayment, and she could not have foreseen 
the negative financial impact that persists on her father’s income from his former partner’s 
criminal activity in 2012. AG ¶ 20(b) applies in that her ability to repay the debt was 
compromised by circumstances beyond her control. As to whether Applicant acted 
responsibly, in response to a collections effort, she made a $300 payment in April 2015, 
which was what she could afford at the time. The creditor was not willing to accept anything 
less than the full monthly payment, which by then was $790. She lived with her parents, 
and it is unclear whether she contributed to the household expenses, but she was earning 
9 
 
only $13.50 an hour. She had living expenses and other student loans to repay. One could 
question Applicant’s financial judgment in that she moved into an apartment from her 
parents’ home in August 2015 and obtained a car loan. The rent and car expenses could 
have instead gone to pay her defaulted student loan.6  Applicant did not explain why she 
moved at that time. However, she held a reasonable belief based on the student loan 
lender’s unwillingness to accept lower, affordable monthly payments that the creditor would 
not work with her toward resolving the debt. 
 
 AG ¶ 20(c) is not established, given the lack of progress toward resolving her 
defaulted student loan. She has also not had financial counseling, although she has a 
budget and has demonstrated that she does not live beyond her means. AG ¶ 20(d) has 
some applicability in that she paid $300 in April 2015 in an effort to demonstrate her good-
faith willingness to make payments toward the delinquency. Applicant re-contacted the 
creditor in October or November 2017 about possible repayment arrangements. She was 
given three repayment options, none of which she could afford. Just two weeks before her 
security clearance hearing, she sent the creditor $200 in an attempt to start repayment, but 
had yet to receive confirmation of its acceptance. Applicant expressed her intention to 
continue to pay $200 a month toward the debt if the creditor accepts her payment. The 
Appeal Board has consistently held that a promise to pay a debt in the future is not a 
substitute for a track record of paying debts in a timely manner. See e.g., ISCR Case No. 
09-05390 at 2 (App. Bd. Oct. 22, 2010). Even so, an applicant is not required, as a matter 
of law, to establish that she has paid off every debt in the SOR. She is required to 
demonstrate that she has established a plan to resolve her financial problems and taken 
significant actions to implement the plan. See ISCR Case No. 07-06482 at 2-3 (App. Bd. 
May 21, 2008) (internal citations and quotation marks omitted). Applicant’s track record of 
payments on her private student loan with lender X and her consolidated federal student 
loan under an income-based debt relief program inspire confidence that she would make 
the $200 monthly payments if the creditor is willing to accept them. 
 
 Even assuming that the creditor is willing to accept $200 monthly payments and that 
she increases her monthly repayment amount once her private student loan with lender X 
and her car loan are paid off, it will be many years before Applicant fully satisfies her 
$68,240 student loan delinquency. It is a substantial debt burden based on her current 
income, even with her overtime earnings. However, student loans are an investment in 
one’s future and do not carry the same judgment concerns as would excessive credit card 
debt. Applicant has no record of irresponsible spending or overreliance on consumer credit 
card debt. It is unlikely that the defaulted student loan will be a source of undue pressure 
for her, given the creditor has written off the debt to profit and loss. While the Government 
has legitimate concerns about Applicant earning college credits that she has not paid for, 
she acted reasonably by attempting to work out affordable repayment terms. 
                                                 
6 When asked on cross-examination whether her cohabitation with her boyfriend since July 2016 has freed up 
money for her to address some of her financial obligations, Applicant responded, “Yes because instead of 
paying $400 in rent I don’t pay the rent. He pays the $800 in rent total and I just pay the extras—electricity, 
phone bill, and cable. (Tr. 69-70.) Applicant clearly reduced her rent expenses, but it is unclear whether the 
$400 was her previous rent or whether she was saving $400 because her boyfriend is not asking her for her 
share of their present rent. 
10 
 
Whole-Person Concept 
 
In assessing the whole person, 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(d). The analysis under Guideline F is incorporated in my whole-
person analysis. Some of the factors in AG ¶ 2(d) were addressed under that guideline, but 
some warrant additional comment. 
 
Applicant’s situation is not unlike that of many students of her generation who take 
out loans for their college education expecting to land a job at some future date at an 
income sufficient to repay them, but then find themselves underemployed when the loans 
come due. Applicant showed sound financial judgment in attempting to minimize her 
college costs by transferring from a private college to her state university at the end of her 
freshman year. Circumstances outside of her control forced her to withdraw from the 
university just one semester short of earning her degree. It had negative consequences for 
her in that it compromised her chances of obtaining employment at an income sufficient to 
repay her student loans and escalated the date on which she was required to begin 
repayment of her student loans. 
 
Applicant obtained a part-time job for a few months in 2015 while working full time 
as an assistant manager for a fast-food establishment. Her willingness to work a second 
job to address her financial obligations shows a positive attitude toward handling her 
finances. She is credited with being willing to start at the bottom as a learner in a trade with 
a defense contractor. She has fulfilled her duties in an exceptional manner, and her 
commitment and progress have been rewarded through non-automatic progressions in pay 
and promotions. Her supervisor attested to her growth having been at an exponential rate. 
She has not displayed behavior that would lead one to doubt her intentions with regard to 
resolving her defaulted student loan under a repayment plan that she can afford on her 
income if given the opportunity. 
 
 The security clearance adjudication involves an evaluation of an applicant’s 
judgment, reliability, and trustworthiness in light of the security guidelines in the Directive. 
See ISCR Case No. 09-02160 (App. Bd. Jun. 21, 2010). It is not intended as a debt 
collection process or designed to punish applicants for past mistakes or shortcomings. 
After considering all the facts and circumstances of record, I conclude that it is clearly 
consistent with the national interest to grant or continue security clearance eligibility for 
Applicant. 
 
Formal Finding 
 
Formal finding for or against Applicant on the allegation set forth in the SOR, as 
required by section E3.1.25 of Enclosure 3 of the Directive, is: 
 
Paragraph 1, Guideline F:  FOR APPLICANT 
 
Subparagraph 1.a:   For Applicant 
11 
 
Conclusion 
 
In light of all of the circumstances, 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