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ISCR Case ISCR Case No. 25-00555 · CASE

Case record

A decided public DOHA case, shown for research, not advice or a prediction.

Decision Date3/27/2026
Statusdenied
LevelHEARING
TypeSTANDARD ISCR
Related decisionsSee the appeal decision (Case ISCR Case No. 25-00555) →See the hearing decision (Case ISCR Case No.25-00555) →
Participants
Applicant Representation: Pro Se
Government Counsel: Andrew H. Henderson, Esq.
Judge: Roger C. Wesley
Guidelines Evaluated
- FFinancial Considerations · Against Applicant
Questions about ISCR ISCR Case No. 25-00555, answered from its own record: what was alleged, what the judge found, where it says so. Descriptive only; never advice.

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Other decisions whose allegations read most like this one. Descriptive similarity of the allegations only, not a prediction.
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ISCR Case ISCR Case No. 25-00555denied

Case Headnote

ISCR Case No. ISCR Case No. 25-00555

deniedMar 27, 2026· Hon. Roger C. Wesley· hearing

Synopsis

The applicant, a 32-year-old employee of a defense contractor, sought a security clearance under Guideline F due to financial considerations. He admitted to accumulating 12 delinquent debts exceeding $24,000 and failed to provide sufficient evidence of resolving these debts. The judge found that the applicant did not mitigate the financial concerns, leading to a denial of his security clearance.

Why the Applicant Was Denied

The applicant accumulated 12 delinquent debts exceeding $24,000, raising concerns about his reliability and judgment.
He failed to provide sufficient evidence of resolving his outstanding debts or demonstrating financial responsibility.
The applicant's claims of working with a credit repair firm did not result in tangible progress in addressing his debts.

Conditions Referenced

Disqualifying

19(a)appliedInability to Satisfy Debts
19(b)appliedUnwillingness to Satisfy Debts Regardless of the Ability to Do So
19(c)appliedA History of Not Meeting Financial Obligations

Mitigating

20(d)appliedThe Individual Initiated and Is Adhering to a Good-faith Effort to Repay Overdue Creditors or Otherwise Resolve Debts

Key Rule Quoted

“Eligibility for access to classified information may only be granted "upon a finding that it is clearly consistent with the national interest to do so."”
Exec. Or. 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960)

Procedural Posture

SOR issuedAug 3, 2025
Answer filedUndated
Hearing heldN/AResolved on the written record without a hearing.
Decision dateMar 27, 2026Decision on remand.

Cite For

Financial Considerations Under Guideline F
Impact of Unresolved Debts on Security Clearance Eligibility
Good-faith Efforts to Resolve Debts as a Mitigating Factor

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 F · descriptive summary of a decided case

Posture: Decision on RecordDecided: denied

The judge found that the applicant had accumulated multiple delinquent debts exceeding $49,000, which raised significant concerns regarding his financial reliability and judgment. Despite some efforts to negotiate settlements, the applicant's financial situation was deemed insufficiently mitigated, leading to a denial of his security clearance.

1.a Applicant accumulated 12 quantified delinquent accounts exceeding $24,000.
$24,000
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.b Applicant has three unquantified delinquent accounts exceeding $25,000.
$25,000
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.c Applicant admitted the allegations pertaining to his delinquent accounts.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.d Applicant negotiated payment settlements with two of the listed SOR creditors.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.e Applicant has made some progress with his reported SOR-listed debts.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.f Applicant retained a credit repair firm to help identify and work with creditors holding delinquent accounts.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.g Applicant's financial situation remains unresolved and outstanding.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.h Applicant's debts raise trust, reliability, and judgment concerns about his current and future ability to manage his finances safely and responsibly.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.i Applicant's admitted debt delinquencies raise judgment issues over the management of his finances.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.j Applicant did not provide persuasive financial reasons why he could not address more of his reported delinquent accounts.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.k Applicant declined to provide evidence of budgeting initiatives, financial counseling, endorsements, or other evidence of reliability, good judgment, and trustworthiness.
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(b) unwillingness to satisfy debts regardless of ability
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a	Applicant accumulated 12 quantified delinquent accounts exceeding $24,000. $24,000	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.b	Applicant has three unquantified delinquent accounts exceeding $25,000. $25,000	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.c	Applicant admitted the allegations pertaining to his delinquent accounts.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.d	Applicant negotiated payment settlements with two of the listed SOR creditors.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.e	Applicant has made some progress with his reported SOR-listed debts.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.f	Applicant retained a credit repair firm to help identify and work with creditors holding delinquent accounts.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.g	Applicant's financial situation remains unresolved and outstanding.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.h	Applicant's debts raise trust, reliability, and judgment concerns about his current and future ability to manage his finances safely and responsibly.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.i	Applicant's admitted debt delinquencies raise judgment issues over the management of his finances.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.j	Applicant did not provide persuasive financial reasons why he could not address more of his reported delinquent accounts.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (c) a history of not meeting financial obligations	—	—
1.k	Applicant declined to provide evidence of budgeting initiatives, financial counseling, endorsements, or other evidence of reliability, good judgment, and trustworthiness.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (b) unwillingness to satisfy debts regardless of ability (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

T OF WAR DEFENSE OFFICE OF HEARINGS AND APPEALS In the matter of: ) ) ) ISCR Case No. 25-00555 ) Applicant

PROCEDURAL HISTORY

or Security Clearance ) Appearances For Government: Andrew H. Henderson, Esq, Department Counsel For Applicant: Pro se 03/27/2026 Decision on Remand WESLEY, ROGER C. Administrative Judge Based upon a review of the case

STATEMENT OF CASE

file, pleadings, exhibits, and testimony, Applicant did not mitigate financial considerations concerns. Eligibility for access to classified information or to hold a sensitive position is denied. Statement of the Case On August 3, 2025, the Defense Counterintelligence and Security Agency Adjudication and Vetting Services (DCSA AVS) issued a statement of reasons (SOR) to Applicant detailing reasons why under the financial considerations guideline the DCSA AVS could not make the preliminary affirmative determination of eligibility for granting a security clearance, and recommended referral to an administrative judge to determine whether a security clearance should be granted, continued, denied, or revoked. The action was taken under Executive Order (Exec. Or.) 10865, Safeguarding Classified Information within Industry (February 20, 1960); Department of Defense (DoD) Directive 5220.6 Defense Industrial Personnel Security Clearance Review Program, (January 2,

1992) (Directive); and Security Execu

PROCEDURAL HISTORY

ive Agent Directive 4, establishing in Appendix A the National Security Adjudicative Guidelines for Determining Eligibility for Access to Classified Information or Eligibility to Hold a Sensitive Position (AGs), effective June 8, 2017. Applicant responded to the SOR (

PROCEDURAL HISTORY

ndated) and requested to have his case resolved on the written record without a hearing. Applicant received the File of Relevant Material (FORM) on September 11, 2025, and he elected to respond to the FORM with a letter of explanation with attachment documenting some payments. This case was assigned to me on January 8, 2026. The Government’s case consisted of eight exhibits that were admitted into evidence without objection as Government Exhibits (GEs 1 through 8). Applicant’s post-FORM submission was admitted into evidence without objection as Applicant’s exhibit A (AE A). Issua

FINDINGS OF FACT

ce of Remand On March 19, 2026, the Appeal Board issued a remand. In its remand, the Appeal Board, the Appeal Board issued instructions to errors identified in the remand and thereafter determine whether or not Applicant sufficiently mitigated the Government’s rem

BACKGROUND

ining concerns under Guideline F and issue a new decision. M Summary of Pleadings Under Guideline F, Applicant allegedly accumulated 11 quantified delinquent debts exceeding $24,000, and three additional unquantified delinquent debts. Allegedly, Applicant’s delinquent debts have not been resolved and remain outstanding. In Applicant’s response to the SOR, he admitted the allegations pertaining to his delinquent accounts. He added explanations and clarifications. He claimed he negotiated payment settlements with

BACKGROUND

wo of the listed SOR creditors (i.e., SOR ¶¶ 1.land 1.m) and attached evidence of payment credits with these creditors. Applicant further claimed to be working with a credit repair firm and has been submitting monthly payments to them since 2024, while enrolled in the firm’s expedited program since June 2025. He claimed also that he will be submitting bank account statements showing proof of his payments. And, he acknowledged his awareness of other pending accounts that “he is slowly but surely resolving” while working with his retained credit repair agency. (GE 1) Findings of Fact Applicant is a 32-year-old employee of a defense contractor who seeks a security clearance. Allegations covered in the SOR and admitted by Applicant are incorporated and adopted as relevant and material findings. Additional findings follow. Background 2

Applicant is unmarried and has no children. (GE 2) He earned a high school diploma in October 2023. Applicant reported no military service. (GE 2) Since January 2024, Applicant has been employed by his current employer as a coatings applicator. (GE 2) Previously, he worked for other employers in various jobs. He has never held a security clearance and is presently sponsored by his current employer. (GEs 2-3) Applicant’s Finances Between 2017 and 2023, Applicant accumulated 12 quantified delinquent accounts exceeding $24,000. (GEs 5-7). Each of these delinquent accounts are addressed in the SOR allegations. (GEs 1-7) Additionally, he accumulated three unquantified delinquent accounts (covered by SOR ¶¶ 1.l-1.n). Together, these three debts exceed $25,000 and bring Applicant’s SOR-listed debt delinquencies to more than $49,000 according to his submitted credit reports. (GEs. 5-7) Applicant has made some progress with his reported SOR-listed debts. Documented is the sale of three of his charged off accounts (i.e., SOR creditors 1.l-1.m and 1.m) to third parties in 2024. (GEs 5-7) While the identity of the creditor 1.mpurchaser matc

POLICIES

es the name of the judgment holder reported in GE 8 (see GE 7), neither the terms of the sale of the $13,200 debt nor the capacity in which the purchaser of the SOR 1.m debt acquired the account (i.e., whether it acquired the SOR creditor 1.maccount for itself (with or without a discount) or as an assigned collection agent for SOR creditor 1.m). Court records do confirm that the acquiring entity of the SOR ¶ 1.maccount sued Applicant in its own name for the full amount of the SOR 1.mdebt and obtained a default judgment in July 2025. (GE 8) This default judgment was, in turn, vacated without prejudice following the parties’ completion of a structured settlement that called for the full payoff of the entered judgment amount of $13,664 in monthly payments of $285. for 48 months. To date, Applicant has paid down the judgment principal with monthly payments totaling $4,500 and is in full compliance with his negotiated settlement agreement. (GEs 2 and 8 and AE A) Applicant’s attachments to his SOR response also identify the same judgment creditor cited in GE 8 as the purchaser of Applicant’s SOR ¶ 1.ldebt (identified as a banking entity). (GE 1) The furnished balance sheet account attached to Applicant’s response credited him with a $270 payment, made in July 2025 on an apparent undated payment plan, leaving a balance owing of $9,434. No other monthly payments on his implicit payment plan with this creditor were documented. Without a copy of the payment plan arranged with the GE 8 creditor, terms and conditions of the plan cannot be traced in Applicant’s credit reports or other submissions in the record for compliance assessment. All that can be discerned from Applicant’s credit reports is that at some time the SOR ¶ 1.ldebt reported in Applicant’s 2024 credit report was a $10,500 charged off debt that was sold to a third party for an undisclosed amount. (GE 5) Piecing together the rest of the history of

POLICIES

. (GE 1) The furnished balance sheet account attached to Applicant’s response credited him with a $270 payment, made in July 2025 on an apparent undated payment plan, leaving a balance owing of $9,434. No other monthly payments on his implicit payment plan with this creditor were documented. Without a copy of the payment plan arranged with the GE 8 creditor, terms and conditions of the plan cannot be traced in Applicant’s credit reports or other submissions in the record for compliance assessment. All that can be discerned from Applicant’s credit reports is that at some time the SOR ¶ 1.ldebt reported in Applicant’s 2024 credit report was a $10,500 charged off debt that was sold to a third party for an undisclosed amount. (GE 5) Piecing together the rest of the history of

PROCEDURAL MATTERS

his debt cannot be made without more information from Applicant. 3

Similarly, the unquantified SOR creditor 1.ndelinquent debt identified in Applicant’s 2024 credit report (GE 5) is reported as a charged-off delinquent debt in the amount of $1,900 that was later sold to another party (with or without a discount) for an undisclosed amount, leaving Applicant with a zero balance. (GE 5) The identity of the third-party purchaser of the debt and what became of this account is undisclosed and unknown. Any meaningful assessment of the payment status of this debt will require more information from Applicant than he has provided to date. To help Applicant to identify and work with his creditors holding delinquent accounts with the goal of resolving them wherever possible, Applicant retained a credit repair firm in September 2024. (GEs 2-3) Under the terms of his agreement with the credit repair firm, he agreed to monthly payments of $149.99 for their services, beginning in September 2024. (GE 2-3) Through Apr

ANALYSIS

l 2025, Applicant documented monthly payments totaling $1,192. (GEs 2-3) What progress this repair firm has made in resolving his individual SOR debts remains undocumented and unclear. In a May 2025 personal financial statement provided by Applicant, he reported net monthly income of $6,100, monthly expenses of $3,275, and a net monthly remainder of $2,825. (GE 4) He did not list any personal debt obligations. For assets, he reported none. (GE 4) Applicant offered no persuasive financial reasons why he could not address more of his reported delinquent accounts with the financial resources available to him. Afforded opportunities to provide evidence of budgeting initiatives, financial counseling, endorsements, performance evaluations, and other evidence of reliability, good judgment, and trustworthiness, Applicant declined to do so. Policies By virtue of the jurisprudential principles recognized by the U.S. Supreme Court in Department of the Navy v. Egan, 484 U.S. 518, 528 (1988), “no one has a ‘right’ to a security clearance.” As Commander in Chief, “the President has the authority to control access to information bearing on national security and to determine whether an individual is sufficiently trustworthy to have access to such information.” Egan. at 527. Eligibility for access to classified information may only be granted “upon a finding that it is clearly consistent with the national interest to do so.” Exec. Or. 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960), as amended. Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the adjudicative guidelines. These guidelines are not inflexible rules of law. Instead, recognizing the complexities of human behavior, these guidelines are applied in conjunction with an evaluation of the whole person. An administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. An administrative judge must consider all available, reliable information about the person, past and present, favorable and unfavorable. 4

The AGs list guidelines to be considered by judges in the decision-making process covering DOHA cases. These guidelines take into account factors that could create a potential conflict of interest for the individual applicant, as well as considerations that could affect the individual’s reliability, trustworthiness, and ability to protect classified information. These AGs include conditions that could raise a security concern and may be disqualifying (disqualifying conditions), if any, and all of the conditions that could mitigate security concerns, if any. These guidelines must be considered before deciding whether or not a security clearance should be granted, continued, or denied. Although, the guidelines do not require judges to place exclusive reliance on the enumerated disqualifying and mitigating conditions in the guidelines in arriving at a decision. In addition to the relevant AGs, judges must take into account the pertinent considerations for assessing extenuation and mitigation set forth in ¶ 2(a) of the AGs, which are intended to assist the judges in reaching a fair and impartial, commonsense decision based on a careful consideration of the pertinent guidelines within the context of the whole person. The adjudicative process is designed to examine a sufficient period of an applicant’s life to enable predictive judgments to be made about whether the applicant is an acceptable security risk. When evaluating an applicant’s conduct, the relevant guidelines are to be considered together with the following ¶ 2(d) factors: (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 of the conduct; (8) the potential for pressure, coercion, exploitation, or duress; and (9) the likelihood of continuation or recurrence. Viewing the issues raised and evidence as a whole, the following individual guidelines are pertinent herein: Financial Considerations The Concern: 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 or 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

WHOLE PERSON ANALYSIS

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 acts or otherwise questionable acts to generate funds. . . . AG ¶ 18. 5

Burdens of Proof

The Government reposes a high degree of trust and confidence in persons with access to classified information. This relationship transcends normal duty hours and endures throughout off-duty hours. Decisions include, by necessity, consideration of the possible risk 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 infor

FORMAL FINDINGS

ation. Clearance decisions must be “in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” See Exec. Or. 10865, Feb. 20, 1960, § 7. See also Exec. Or. 12968 (Aug. 2, 1995), § 3.1. Initially, the Government must establish, by substantial evidence, conditions in the personal or professional history of the applicant that may disqualify the applicant from being eligible for access to classified information. The Government has the burden of establishing controverted facts alleged in the

CONCLUSION

OR. See Egan, 484 U.S. at 531. “Substantial evidence” is “more than a scintilla but less than a preponderance.” See v. Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines presume a nexus or rational connection between proven conduct und