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ISCR Case 16-02367.h1 — CASE

ISCR Case 16-02367.h1denied

Case Headnote

ISCR Case No. 16-02367.h1

deniedJul 1, 2016· Hon. Braden M. Murphy· hearing

Summary

A 64-year-old truck driver was denied a security clearance due to concerns under Guideline E (Personal Conduct) and Guideline F (Financial Considerations). The Statement of Reasons detailed numerous financial delinquencies, including $900 in past-due state taxes, an unfiled 2014 state income tax return, a past-due home mortgage, two large delinquent credit cards, a $588 debt to a phone company, and multiple medical and various consumer debts.

Additionally, the applicant was alleged to have deliberately failed to disclose the full extent of these delinquencies on her security clearance application. While she successfully rebutted the allegation of falsification, she did not provide sufficient evidence to mitigate the financial concerns.

The denial was based on the applicant's failure to demonstrate responsible action regarding her numerous delinquent debts, which raised questions about her reliability and trustworthiness. Insufficient evidence was provided to show that her financial issues were being resolved or were under control.

Why the Applicant Prevailed

Applicant rebutted the falsification allegation under Guideline E by providing credible explanations for her financial disclosures.

Conditions Referenced

Disqualifying

AG ¶ 19(a)raisedInability or Unwillingness to Satisfy Debts
AG ¶ 19(c)raisedA History of Not Meeting Financial Obligations
AG ¶ 19(g)rejectedFailure to File Annual Federal, State or Local Income Tax ReturnsThe Government did not meet its burden of establishing that the applicant failed to file her 2014 state income tax return.

Mitigating

AG ¶ 20(b)appliedConditions That Resulted in the Financial Problem Were Largely Beyond the Person's ControlApplicant's financial difficulties began after serious injuries from accidents, impacting her ability to work.
AG ¶ 20(d)rejectedGood-faith Effort to Repay Overdue CreditorsApplicant did not provide sufficient evidence of a realistic plan to resolve her debts.

Key Rule Quoted

“The protection of the national security is the paramount consideration.”

Procedural Posture

SOR issuedSep 30, 2016
Answer filedOct 10, 2016Applicant elected to have her case decided on the written record.
Hearing held—No hearing; case decided on the written record.
Decision dateApr 24, 2017

Cite For

Rebuttal of Falsification Allegations Under Guideline E
Insufficient Evidence of Financial Responsibility Under Guideline F
Impact of Personal Circumstances on Financial Obligations

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

Standardized Decision Profile

SEAD-4 Guideline E (Personal Conduct) · descriptive summary of a decided case

Posture: Decision on RecordDecided: denied

The judge found that the applicant rebutted the personal conduct allegations under Guideline E. Specifically, the judge concluded that the applicant did not intentionally provide false information on her security clearance application, resulting in a favorable finding for the applicant on the relevant subparagraph.

¶	Allegation	Finding	Conduct	Concealed Issue	Response	Disqualifying (¶16)	Mitigating applied (¶17)	Mitigation
2.a	Applicant deliberately failed to disclose the full extent of her delinquencies on her SCA.	For Applicant	Omission or Failure to Disclose	—	Denied	—	—	—

Descriptive standardized rendering of a decided public case (Guideline E). The verbatim source decision is shown in full below.

Standardized Decision Profile

SEAD-4 Guideline F · descriptive summary of a decided case

Posture: Decision on RecordDecided: denied

The judge found multiple financial concerns under Guideline F, including unpaid debts and a history of not meeting financial obligations. While some debts were resolved, the applicant failed to provide sufficient evidence of responsible action to mitigate the ongoing financial issues, leading to a denial of the security clearance.

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a	owed $900 in past-due state taxes $900	For Applicant	Tax Unpaid	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.b	failed to file her 2014 state income tax return	For Applicant	Tax Filing Failure	Denied	(g) unexplained affluence	—	—
1.c	past-due home mortgage $13,072	Against Applicant	Mortgage or Home Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.d	a large delinquent credit card	Against Applicant	Credit Card Debt	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.e	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.f	$588 debt to a phone company $588	Against Applicant	Utility or Phone Debt	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.g	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.h	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.i	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.j	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.k	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.l	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.m	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.n	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.o	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.p	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.q	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.r	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.s	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.t	medical debts	Against Applicant	Medical Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.u	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.v	various consumer debts	For Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.w	a large delinquent credit card	For Applicant	Credit Card Debt	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.x	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.y	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.z	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.aa	various consumer debts	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—

Descriptive standardized rendering of a decided public case (Guideline F). The verbatim source decision is shown in full below.

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

HEARING

APPEARANCES

DEPARTMENT OF DEFENSE DEFENSE OFFICE OF HEARINGS AND APPEALS

In the matter of: ) ) ) ISCR Case No. 16-02367 ) Applicant for Security Clearance )

For Government: Bryan Olmos, Esq., Department Counsel For Applicant: Pro se

04/24/2017 ______________

STATEMENT OF CASE

______________

MURPHY, Braden M., Administrative Judge:

Applicant rebutted the falsification allegation under Guideline E, personal conduct, but failed to demonstrate that she has mitigated the security concerns under Guideline F, financial considerations. Applicant’s eligibility for access to classified information is denied.

Statement of the Case

On September 30, 2016, the Department of Defense (DOD) issued Applicant a Statement of Reasons (SOR) detailing security concerns under Guideline F, financial considerations and Guideline E, personal conduct. The action was taken under Executive Order (EO) 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; DOD Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines effective within the DOD for SORs issued after September 1, 2006. Applicant initially answered the SOR on October 10, 2016, and elected to have her case decided on the written record in lieu of a hearing. She submitted a second, more complete answer on October 26, 2016. On December 16, 2016, Department Counsel submitted the Government’s file of relevant material (FORM). The Government submitted documents identified as Items 1 through 7. Applicant received the FORM on January 4, 2017. Applicant was afforded an opportunity to file objections and submit material in refutation, extenuation, or mitigation. Applicant’s undated FORM response was received by DOHA on or about January 9, 2017.1 She did not object to the Government’s evidence. Items 1, 2 and 3 are the pleadings in the case. Items 4 through 7 are admitted into evidence without objection. Applicant’s FORM response is marked Applicant’s Exhibit (AE) A and is admitted into evidence without objection. The case was assigned to me on April 13, 2017.

FINDINGS OF FACT

Applicant admitted all the SOR allegations but for SOR ¶¶ 1.a, 1.band 1.d, with explanations. I have incorporated her answers and relevant comments into the findings of fact. After a thorough and careful review of the pleadings and exhibits submitted, I make the following findings of fact.

Applicant is 64 years old. She and her husband have been married since 1970. They have one adult daughter. Since at least 2003, she has worked for a variety of companies as a long-haul truck driver making deliveries nationwide. She has had the same employer, a federal contractor, since April 2015.2

Applicant was seriously injured in an accident in November 2011 when her leg was run over by the truck, driven by her husband. She was hospitalized for about six weeks, and underwent numerous surgeries. In July 2013, she had both knees replaced. In October 2013, she and her husband were in a roll-over accident. She was again hospitalized, with broken ribs and other serious injuries. Her husband subsequently lost his job, and Applicant was unable to return to work until March 2014.3

Applicant completed a security clearance application (SCA) in September 2015. She disclosed that she filed her 2014 state income tax return late and owed $900 in past- due state taxes (SOR ¶¶ 1.a and b), as well as a large delinquent credit card (SOR ¶ 1.d), and stated she was making payments on both.4

Applicant has numerous other delinquent debts, all set forth on credit reports from September 2015 and June 2016, and alleged in the SOR. The SOR debts total about $30,741. Most of the debts she had accrued by the fall of 2015 are medical accounts and consumer debts.5 More recent debts include a past-due home mortgage (SOR ¶ 1.c).6

Applicant did not disclose that she had any other delinquent debts on her SCA, beyond the tax debt and the single credit card account. In answering SOR ¶ 2.a, Applicant states, in part, “I wasn’t trying to be smart or disrespectful to anyone. I answered the best that I could.”7 I construe her answer as a denial to the Guideline E allegation that she deliberately failed to disclose the full extent of her delinquencies on her SCA.

Applicant denies failing to file her 2014 state income tax return as required, and denies owing the state $900 in past-due taxes (SOR ¶¶ 1.a and 1.b). The allegation is supported by her own disclosure of the matter on her SCA and in her background interview.8 She states the debt has been paid in full, and was resolved when the state kept a portion of her “return” (i.e., refund) this year. This statement is not supported by corroborating documentation. However, it is consistent with Applicant’s statements on her SCA and in her interview, in which she states that due to a job loss, she filed her 2014 state tax return in April 2015 (which, if true, means if the filing was late at all it would have been late by a few weeks at most)) and entered into a $100-a-month payment plan.9 Applicant’s tax issues are limited to the 2014 tax year. Though her answers are unsupported by documentation, I nonetheless find them credible.

Applicant also denies SOR ¶ 1.d, though she reported it as delinquent on her SCA. The debt is listed as charged off on her June 2016 credit report. Applicant states that the debt was refinanced and closed. This answer is unsupported by documentation. Applicant provides insufficient evidence that this debt is being resolved.

Applicant admits SOR ¶ 1.c, a past-due mortgage loan for $13,072. She says the loan matured in March 2015, and that she has been paying $700 every other week on the debt. In AE A, she states that she now owes $8,800 on the debt and is in settlement discussions with the creditor. These answers are unsupported by documentation. Applicant provides insufficient evidence that this debt is being resolved.

Applicant admits the remaining debts. These include various consumer and utility debts (SOR ¶¶ 1.e, 1.f, 1.g, 1.m, 1.o, 1.u, 1.v, and 1.aa) and medical debts (SOR ¶¶ 1.h- 1.l, 1.n, 1.p-1.t, and 1.x-1.z). Most of the medical debts are not specifically identified in the SOR, though some of them have named collection agencies in the credit reports.10 She explains that her debts resulted from her various surgeries and medical procedures. Her resulting time away from work, and her husband’s job loss both impacted their finances and their ability to pay the debts.

Applicant is contesting SOR ¶ 1.e (a $2,295 debt to a phone company). She says she is making $99 monthly payments on SOR ¶ 1.f ($588). She indicates that she has a list of her medical debts and is paying the smaller ones first, though she provides no specifics or documentation. She states that SOR ¶ 1.aa ($126) has been paid. She has contacted several of her other creditors in an attempt to negotiate payments. She provides no documents concerning these efforts. She also provides no documentation about her monthly income and expenses.11

POLICIES

When evaluating an applicant’s suitability for a security clearance, the administrative judge must consider the adjudicative guidelines (AG). In addition to brief introductory explanations for each guideline, the adjudicative guidelines list potentially disqualifying conditions and mitigating conditions, which are used 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 overarching 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. Likewise, I have avoided drawing inferences grounded on mere speculation or conjecture.

Under Directive ¶ E3.1.14, the Government must present evidence to establish controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, an “applicant is responsible for presenting witnesses and other evidence to rebut, explain, extenuate, or mitigate facts admitted by applicant or proven by Department Counsel, and has the ultimate burden of persuasion as to obtaining 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 an applicant may deliberately or inadvertently fail to safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation as to 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).

ANALYSIS

Guideline F, Financial Considerations

The security concern relating to the guideline for financial considerations is set out 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.

This concern 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. An individual who is financially irresponsible may also be irresponsible, unconcerned, or negligent in handing and safeguarding classified information.12

AG ¶ 19 provides conditions that could raise security concerns. The following are potentially applicable:

(a) inability or unwillingness to satisfy debts;

(g) failure to file annual Federal, state or local income tax returns, or the fraudulent filing of the same. Applicant denies SOR ¶ 1.a, concerning her failure to file her 2014 state income tax return. Applicant disclosed that she filed the return in April 2015, acknowledging that she owed about $900 in past-due taxes. Applicant’s federal and state income tax returns for tax year 2014 would have been due on or about April 15, 2015 – the same month Applicant has stated that she filed her 2014 state return. Although this return is not in the record, I cannot find that the Government has met its burden of establishing that AG ¶ 19(g) applies to SOR ¶ 1.a.

Applicant’s various delinquent debts are established by the record. There is sufficient evidence to support the application of disqualifying conditions AG ¶¶ 19(a) and 19(c).

Applicant’s $900 state tax debt has been paid. I resolve SOR ¶ 1.bfor Applicant. SOR ¶¶ 1.dand 1.ware the same debts. I resolve SOR ¶ 1.wfor Applicant since it is a duplicate.13

The guideline also includes conditions that could mitigate security concerns arising from financial difficulties. The following mitigating conditions under AG ¶ 20 are potentially applicable:

(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, or a death, divorce or separation), and the individual acted responsibly under the circumstances;

(c) the person has received or is receiving counseling for 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.

Applicant’s financial difficulties began after she was seriously injured in two truck accidents, in 2011 and 2013, leading to multiple surgeries and causing her to miss work while recovering for a significant period of time. During her second recovery period, her husband also lost his job, in 2014. These are all circumstances beyond her control. The first prong of AG ¶ 20(b) applies. However, for the full application of AG ¶ 20(b), Applicant must provide evidence that she acted responsibly under the circumstances. She has not provided sufficient evidence of responsible action. For some of her debts, she indicates that the debt is resolved, but she has not provided corroborating documentation.14 For most of her debts, Applicant has not set forth a realistic plan for resolving them. The second prong of AG ¶ 20(b) does not apply.

Applicant’s delinquent debts are ongoing and not isolated. There is insufficient evidence that her financial issues are unlikely to recur. They continue to cast doubt on his current reliability, trustworthiness, and good judgment. AG ¶ 20(a) does not apply.

Applicant provides no evidence of financial counseling. She provides no evidence of her monthly income and expenses. Without additional evidence, there are not clear indications that Applicant’s financial problems are being resolved or are under control. AG ¶ 20(c) does not apply.

Applicant indicates that she is making payments on some of her debts, and looking into others. She has not provided corroborating documentation of any payments she has made. She has not provided sufficient evidence to establish that she has a reasonable plan to resolve her debts, or that she has taken steps towards establishing a reliable financial track record. AG ¶ 20(d) does not apply.

Guideline E

The security concern for personal conduct is set out in AG ¶ 15, as follows:

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.

AG ¶ 16 describes conditions that could raise a security concern and may be disqualifying. The following disqualifying condition is potentially applicable:

(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.

Applicant disclosed a past-due tax debt and a $9,843 delinquent debt on her SCA. She did not disclose other delinquent debts. The information she provided about her finances, however, is sufficient to rebut the allegation of deliberate falsification. Applicant did not intentionally provide false information on her SF 86. AG ¶ 16(a) is not applicable. SOR ¶ 2.a is concluded for Applicant.15

WHOLE PERSON CONCEPT

Under the whole-person concept, the administrative judge must evaluate an applicant’s eligibility for a security clearance by considering the totality of the applicant’s conduct and all the circumstances. The administrative judge should consider the nine adjudicative process factors listed at AG ¶ 2(a):

(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.

Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a security clearance must be an overall commonsense judgment based upon careful consideration of the guidelines and the whole-person concept.

I considered the potentially disqualifying and mitigating conditions in light of all the facts and circumstances surrounding this case. I have incorporated my comments under Guidelines F and E in my whole-person analysis. Some of the factors in AG ¶ 2(a) were addressed under these guidelines, but some warrant additional comment.

Applicant is a 64-year-old truck driver. Her financial problems began several years ago after she was seriously injured in two truck accidents, resulting in multiple surgeries and time away from work. She did not intend to falsify her SCA concerning her finances. She has not shown sufficient corroborating documentary evidence that she has undertaken responsible action to pay or otherwise resolve her delinquencies, which are ongoing. Applicant does not have a reliable financial track record at this time. Her finances remain a security concern. She has failed to meet her burden of persuasion. The record evidence leaves me with questions and doubts as to Applicant’s eligibility and suitability for a security clearance. For all these reasons, I conclude Applicant rebutted the Guideline E personal conduct security concern but failed to mitigate the security concerns arising under Guideline F, financial considerations.

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.b: For Applicant Subparagraphs 1.c-1.v: Against Applicant Subparagraph 1.w: For Applicant Subparagraphs 1.x-1.aa: Against Applicant

Paragraph 2, Guideline E: FOR APPLICANT

Subparagraph 2.a: For Applicant

CONCLUSION

In light of all of the circumstances presented by the record in this case, it is not clearly consistent with the national interest to grant Applicant’s eligibility for a security clearance. Eligibility for access to classified information is denied.

_____________________________ Braden M. Murphy Administrative Judge

FOOTNOTES

1 In AE A, Applicant provided updated information about each SOR allegation, along with a copy of the Government’s FORM and two of its attachments, but she provided no documents of her own. 2 Item 4. 3 Item 2. 4 Item 4. 5 Item 6. 6 Items 6, 7. 7 Item 3. 8 Items 4, 5. 9 Id. 10 Items 2, 3, 6, 7. 11 AE A. 12 See ISCR Case No. 11-05365 at 3 (App. Bd. May 1, 2012). 13 When the same conduct is alleged twice in the SOR under the same guideline, one of the duplicative allegations should be resolved in Applicant’s favor. See ISCR Case No. 03-04704 at 3 (App. Bd. Sep. 21, 2005) (same debt alleged twice). 14 It is reasonable to expect Applicants to present documentation about the satisfaction of individual debts. ISCR Case No. 07-10310 at 2 (App. Bd. Jul. 30, 2008). 15 In addition, Applicant’s home loan (SOR ¶ 1.c) was current in September 2015, though it later became past due. Item 6 at 4; Item 7 at 1. Thus, its reference in Guideline E SOR ¶ 2.a as a delinquent debt that Applicant should have disclosed on her September 2015 SCA is not supported by the record.