Loading case…

ISCR 24-02473: Guideline F security clearance appeal, denied (2026) · CASE

ISCR Case 24-02473denied

Case headnote

ISCR Case No. 24-02473

Jan 12, 2026· Hon. Moira D. Modzelewski· appeal

Summary

A security clearance applicant, representing herself, was denied under Guideline F (Financial Considerations) due to significant financial issues. These included a Chapter 7 bankruptcy and multiple delinquent debts exceeding $10,000. The applicant admitted to these debts, which were identified as disqualifying conditions under Adjudicative Guideline (AG) ¶ 20.

While the applicant presented some documentation, the judge determined it was insufficient to mitigate the financial concerns. Specifically, the applicant failed to provide adequate evidence of payments or resolution for the outstanding debts. Consequently, the judge found that the applicant did not establish a sufficient record of responsible financial conduct.

Despite the application of mitigating conditions under AG ¶ 21(a), (b), (c), and (d), the lack of sufficient evidence regarding debt resolution led to the denial of the security clearance. This denial was subsequently affirmed on appeal.

Conditions referenced

Disqualifying

AG ¶ 20raisedFinancial Considerations

Mitigating

AG ¶ 21(a)rejectedThe Behavior Was Not RecentThe applicant's financial issues were ongoing and not resolved.
AG ¶ 21(b)rejectedThe Conditions That Resulted in the Financial Problems Were Largely Beyond the Person's ControlThe applicant did not demonstrate that her financial issues were beyond her control.
AG ¶ 21(c)rejectedThe Person Has Received or Is Receiving Counseling for the ProblemThe applicant did not provide evidence of financial counseling.
AG ¶ 21(d)rejectedThe Person Has Initiated a Good-faith Effort to Repay Overdue Creditors or Otherwise Resolve DebtsThe applicant's efforts to resolve debts were deemed insufficient.

Key rule quoted

“The general standard is that a clearance may be granted only when 'clearly consistent with the interests of the national security.'”
Department of the Navy v. Egan, 484 U.S. 518, 528 (1988)

Procedural posture

SOR issuedFeb 13, 2025
Answer filed—
Hearing held—
Decision dateJan 12, 2026Appeal affirmed the denial.

Cite for

Affirmation of Denial Based on Financial Considerations Under Guideline F
Insufficient Evidence of Debt Resolution
Importance of Demonstrating Responsible Financial Conduct for Security Clearance Eligibility

Editorial summary generated for research. Not legal advice; not a prediction. Verify against the full decision before relying on any quoted language.

Appeal at a glance· Full written decision

Affirmed

The appeal involved a denial of security clearance based on financial considerations, specifically a Chapter 7 bankruptcy and multiple delinquent debts. The Applicant argued that evidence of payments was not properly submitted. The Board affirmed the Administrative Judge's decision, finding no harmful error in the evaluation of evidence and concluding that the Applicant did not mitigate the financial concerns.

Appealed bythe applicant

Applicant representationPro se (self-represented)

Judge belowRichard A. Cefola denied the clearance

Decided ona hearing

Guidelines belowGuideline F

What the Board reviewed

Judge mis-weighed or ignored evidence, raised by the applicantRejected
Applicant contended that proof of payments was not properly submitted due to a scanning or transmission error.
Decision arbitrary, capricious, or contrary to law, raised by the applicantRejected
Applicant argued that the Judge's conclusions were arbitrary and capricious.

Error found, but harmless. The Board agreed the judge made a mistake but affirmed anyway, because it did not change the outcome.

Why the Board ruled this way

The Board found no harmful error in the Judge's findings and concluded that the evidence did not support the Applicant's claims of payment, affirming the denial of the security clearance.

Standard of review applied

Harmful-error gatekeeperSubstantial-evidence reviewArbitrary-and-capricious reviewProcedural complianceNo de-novo re-decisionNo new evidence on appealDeference to the judge’s credibility calls

Appeal Board panel

Moira Modzelewski (Chair)
Allison Marie
Jennifer I. Goldstein

Descriptive structured reading of this decided, public Appeal Board decision: what the case says, not a prediction or advice.

Full decision

The complete, official text, footnotes and signatures included, is in the original PDF.

Decision text, by section

DEFENSE OFFICE OF HEARINGS AND APPEALS

APPEAL

APPEARANCES

_______________________________________ ) In the matter of: )

)

------------- )

ISCR Case No. 24-02473

)

) Applicant for Security Clearance ) _______________________________________) DEPARTMENT OF DEFENSE DEFENSE LEGAL SERVICES AGENCY DEFENSE OFFICE OF HEARINGS AND APPEALS APPEAL BOARD POST OFFICE BOX 3656 ARLINGTON, VIRGINIA 22203 (703) 696-4759 Date: January 12, 2026

APPEAL BOARD DECISION

APPEARANCES

FOR GOVERNMENT Andrea M. Corrales, Esq., Deputy Chief Department Counsel FOR APPLICANT Pro se The Department of Defense (DoD) declined to grant Applicant a security clearance. On February 13, 2025, DoD issued a Statement of Reasons (SOR) advising Applicant of the basis of that decision – security concerns raised under Guideline F (Financial Considerations) of the National Security Adjudicative Guidelines (AG) in Appendix A of Security Executive Agent Directive 4 (effective June 8, 2017) and DoD Directive 5220.6 (Jan. 2, 1992, as amended) (Directive). On December 4, 2025, Defense Office of Hearings and Appeals Administrative Judge Richard A. Cefola denied Applicant national security eligibility. Applicant appealed pursuant to Directive ¶¶ E3.1.28 and E3.1.30.

DISCUSSION

The SOR alleged that Applicant filed Chapter 7 bankruptcy in 2020 and discharged her debt in November 2020 in SOR ¶ 1.a. Additionally, it alleged 13 delinquent debts (several of the debts were duplicated on the SOR). SOR ¶ 1.rwas withdrawn by the Government at hearing. Transcript (Tr.) at 50-51. In her response to the SOR, Applicant admitted all of the debts and

provided explanations and documents. The Judge found against her on SOR ¶¶ 1.b, 1.c, 1.e, 1.s, and 1.t, which represent four unique debts totaling over $10,000 that appear to remain delinquent.1 On appeal, Applicant contends that, “Due to an apparent scanning or transmission error, proof of these payments was not properly submitted.” Appeal Brief at 1. She further noted that she was resubmitting all relevant documentation with her appeal. Id. She attached a one-page document to her brief relating to the debt identified in SOR ¶ 1.b (and duplicated in SOR ¶ 1.t), which she contends was lost in transmission. Id. at 3. However, the Judge reviewed the document she contends was lost. The one-page document attached to her brief document was also attached to Applicant’s Answer to the SOR. He noted this when discussing this debt: 1.b. and 1.t. are one and the same past-due debt. Applicant admits that she was indebted to Creditor A in the amount of about $5,276. She has submitted a letter from the successor creditor of this debt, showing that said creditor has agreed to accept half payment in March of 2025, and monthly payments of $233, thereafter. Applicant avers that she made the half payment, and “like [about] seven” monthly payments pursuant to the agreement. However, despite having more than a month to do so, Applicant has submitted nothing further in this regard. (TR at page 33 line 12 to page 41 line 13, and Answer at attachment 1.) These allegations are found against Applicant. Decision at 2 (emphasis added). It is clear that the Judge reviewed the document in question and found that it failed to establish that Applicant had made any payments. Based on our review of the record, we find no error in the Judge’s finding that Applicant did not provide documentary evidence to corroborate her claim that the delinquent debt discussed above was resolved. We find that the Judge reasonably concluded that Applicant had not established a sufficient record of payments and responsible financial conduct with respect to this debt. Applicant’s “disagreement with the Judge’s weighing of the evidence, or an ability to argue for a different interpretation of the evidence, is not sufficient to demonstrate that the Judge weighed the evidence or reached conclusions in a manner that is arbitrary, capricious, or contrary to law.” ISCR Case No. 06-17409, 2007 WL 4105312 at *2 (App. Bd. Oct. 12, 2007). Moreover, Applicant’s argument fails to rebut the presumption that the Judge considered all of the record evidence. The Judge’s conclusion that Applicant failed to mitigate the financial security concerns is sustainable. The Judge examined the relevant evidence and articulated a satisfactory explanation for the decision. The decision is sustainable on this record. “The general standard is that a clearance may be granted only when “clearly consistent with the interests of the national security.” Department of the Navy v. Egan, 484 U.S. 518, 528 (1988). “Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). 1 The Judge’s failure to find for Applicant on one of the debts alleged in duplicate (SOR ¶ 1.band SOR ¶ 1.t) is harmless error, as he explicitly recognized the duplication.

ORDER

The decision in ISCR Case No. 24-02473 is AFFIRMED. Signed: Moira Modzelewski Moira Modzelewski Administrative Judge Chair, Appeal Board Signed: Allison Marie Allison Marie Administrative Judge Member, Appeal Board Signed: Jennifer I. Goldstein Jennifer I. Goldstein Administrative Judge Member, Appeal Board