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ISCR Case ISCR Case No. 25-01162 · CASE

Case record

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

Decision Date6/17/2026
Statusdenied
LevelHEARING
TypeWRITTEN RECORD FORM
Participants
Applicant Representation: Pro Se
Government Counsel: Carroll J. Connelley
Judge: Richard A. Cefola
Guidelines Evaluated
- EPersonal Conduct · Against Applicant
- FFinancial Considerations · Against Applicant
Questions about ISCR ISCR Case No. 25-01162, answered from its own record: what was alleged, what the judge found, where it says so. Descriptive only; never advice.

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ISCR Case ISCR Case No. 25-01162denied

Case Headnote

ISCR Case No. ISCR Case No. 25-01162

deniedJun 17, 2026· Hon. Richard A. Cefola· hearing

Synopsis

The applicant, a 43-year-old electronic technician with a history of financial difficulties and personal conduct issues, faced security clearance denial under Guideline E (Personal Conduct) and Guideline F (Financial Considerations). The applicant admitted to significant delinquent debts exceeding $182,000 and unresolved tax issues totaling over $9,800, failing to provide a credible plan for resolution. The judge found that the applicant's financial problems and lack of candor raised serious doubts about her reliability and trustworthiness.

Why the Applicant Was Denied

The applicant admitted to all debts and tax issues alleged in the SOR.
The applicant failed to file federal tax returns for 2021 and 2022 and did not provide a plan to address her tax debts.
The applicant did not demonstrate a good-faith effort to repay her debts or resolve her financial issues.

Conditions Referenced

Disqualifying

AG ¶ 19(a)raisedInability to Satisfy Debts
AG ¶ 19(c)raisedA History of Not Meeting Financial Obligations
AG ¶ 19(f)raisedFailure to File or Fraudulently Filing Annual Federal, State, or Local Income Tax Returns or Failure to Pay Annual Federal, State, or Local Income Tax as Required
AG ¶ 16(a)raisedDeliberate Omission, Concealment, or Falsification of Relevant Facts
AG ¶ 16(b)raisedDeliberately Providing False or Misleading Information

Key Rule Quoted

“Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.”

Procedural Posture

SOR issuedOct 29, 2025
Answer filedNov 20, 2025Requested decision on written record.
Hearing held—No hearing; decided on written record.
Decision dateJun 17, 2026

Cite For

Denial of Security Clearance Due to Unresolved Financial Issues Under Guideline F
Lack of Candor in Security Clearance Application Under Guideline E
Failure to Demonstrate 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 E (Personal Conduct) · descriptive summary of a decided case

Posture: Decision on RecordDecided: denied

The judge found against the applicant on the personal conduct allegations under Guideline E. The applicant's responses to the security questionnaire were deemed to lack candor, which raised concerns about her reliability and trustworthiness.

2.a False Statement ONE in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you failed to file or pay Federal, state, or other taxes when required by law or ordinance?” Applicant admitted to the allegation in her answer, but qualified her statement explaining, “I admit, but I answered no thinking I could get a refund. I wasn’t trying to mislead.” (Answer)
Finding: Against Applicant
Conduct: Lack of Candor in InterviewFOUND DELIBERATE
Concealed issue: Other
Response: Admitted
Disqualifying (¶16):
(a) deliberate omission, concealment, or falsification on a security form
(c) credible adverse information across areas supporting a whole-person concern
(f) violation of a written commitment made as a condition of employment
Mitigating applied (¶17): —
Mitigation: —
2.b False Statement TWO in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you had a judgment entered against you?” Applicant admitted to the allegation in her Answer, but qualified her statement explaining, “I admit, but don’t understand what judment (sic) against me is.” (Answer)
Finding: Against Applicant
Conduct: Lack of Candor in InterviewFOUND DELIBERATE
Concealed issue: Other
Response: Admitted
Disqualifying (¶16):
(a) deliberate omission, concealment, or falsification on a security form
(c) credible adverse information across areas supporting a whole-person concern
(f) violation of a written commitment made as a condition of employment
Mitigating applied (¶17): —
Mitigation: —

¶	Allegation	Finding	Conduct	Concealed Issue	Response	Disqualifying (¶16)	Mitigating applied (¶17)	Mitigation
2.a	False Statement ONE in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you failed to file or pay Federal, state, or other taxes when required by law or ordinance?” Applicant admitted to the allegation in her answer, but qualified her statement explaining, “I admit, but I answered no thinking I could get a refund. I wasn’t trying to mislead.” (Answer)	Against Applicant	Lack of Candor in InterviewFOUND DELIBERATE	Other	Admitted	(a) deliberate omission, concealment, or falsification on a security form (c) credible adverse information across areas supporting a whole-person concern (f) violation of a written commitment made as a condition of employment	—	—
2.b	False Statement TWO in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you had a judgment entered against you?” Applicant admitted to the allegation in her Answer, but qualified her statement explaining, “I admit, but don’t understand what judment (sic) against me is.” (Answer)	Against Applicant	Lack of Candor in InterviewFOUND DELIBERATE	Other	Admitted	(a) deliberate omission, concealment, or falsification on a security form (c) credible adverse information across areas supporting a whole-person concern (f) violation of a written commitment made as a condition of employment	—	—

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 significant delinquent debts and unresolved tax issues. The applicant admitted to the debts but failed to provide evidence of any payments or plans to resolve them, leading to a decision against her on all relevant allegations.

1.a Failure to File Federal Tax Returns (2021 - 2022)
Finding: Against Applicant
Type: Tax Filing Failure
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
(f) failure to file / fraudulent filing of tax returns or unpaid tax
Mitigating applied (¶20): —
Mitigation: —
1.l Bank B Credit Card – Charge Off ($10,255)
$10,255
Finding: Against Applicant
Type: Credit Card Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.m Bank A Credit Card – Charge Off ($20,650)
$20,650
Finding: Against Applicant
Type: Credit Card Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a	Failure to File Federal Tax Returns (2021 - 2022)	Against Applicant	Tax Filing Failure	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations (f) failure to file / fraudulent filing of tax returns or unpaid tax	—	—
1.l	Bank B Credit Card – Charge Off ($10,255) $10,255	Against Applicant	Credit Card Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.m	Bank A Credit Card – Charge Off ($20,650) $20,650	Against Applicant	Credit Card Debt	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

nces For Government: Carroll J. Connelley, Esq., Department Counsel F

DECISION

r Applicant: Pro se 06/17/2026 Decision CEFOLA, Richard A., Administrative Judge: Applicant did not mitigate the security concerns under Guideline E (Personal Conduct) and Guideline F (Financial Consideration

STATEMENT OF CASE

). Eligibility for access to classified information is denied. Statement of the Case Applicant submitted a Questionnaire for National Security Positions on June 13, 2025 (Questionnaire). On October 29, 2025, the Defense Counterintelligence and Security Agency (DCSA) issued a Statement of Reasons (SOR) to Applicant detailing security concerns under Guideline E (Personal Conduct) and Guideline F (Financial Considerations). The action was taken under Executive Order 10865, Safeguarding Classified Information Within Industry (February 20, 1960), as amended; Department of Defense (DoD) Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) effective within DoD after June 8, 2017.

FINDINGS OF FACT

On November 20, 2025, Applicant responded to the SOR in writing (Answer) and requested that this case be decided on the written record in lieu of a hearing. In her Answer, she admitted to all the debt and tax issues alleged in the SOR. On March 23, 2026, Department Counsel submitted the Government’s written case in a File of Relevant Material (FORM). A complete copy of the FORM, consisting of Government’s Exhibits (GE) 1 to 12 and the Government’s arguments in support of the SOR, was received by the Applicant on April 9, 2026. She was afforded an opportunity to file objections and submit material to refute, extenuate, or mitigate the security concerns, but did not respond within the specified 30-day period. The case was assigned to me on June 12, 2026, and all exhibits were admitted without objection. Findings of Fact Applicant is 43 years old and has worked for a DoD contractor since 2002 as an electronic technician. Applicant completed her first application for a security clearance in connection with her present employment. She is single and has one minor child. She immigrated to the United States from Vietnam when she was 15 and was naturalized in 1998. She received an associate’s degree as an electronic technician in 2000. (GE 2 at 5, 9-10, 13, 18, 23) SOR Paragraph 1, Guideline F (Financial Considerations) The Government alleged that Applicant is ineligible for a security clearance because she has delinquent debts and unresolved tax issues, including consumer debts totaling over $182,000 and tax arrears in excess of $9,800. The following facts pertain: 1.a. Failure to File Federal Tax Returns (2021 - 2022): Applicant admitted not filing her 2021 and 2022 federal tax returns in her Answer but denied any failure to file or pay taxes in her Questionnaire. Applicant has provided no information as to why she did not file these tax returns and has not proffered a plan to handle this issue. (Answer; GE 2 at 24; GE 3 at 5; GE 7 at 5-6) 1.b. Federal Tax Debt - $9,371 (2019): Applicant admitted to these arrears in her Answer but denied any failure to file or pay taxes in her Questionnaire. She filed the federal tax return for that year but has not settled the debt. Applicant did not provide any information about any plans she might have to pay back taxes. (Answer; GE 2 at 24; GE 7 at 1) 1.c. Federal Tax Debt - $490 (2023): Applicant admitted to these arrears in her Answer but denied any failure to file or pay taxes in her Questionnaire. She filed the federal tax return for that year but has not settled the debt. Applicant did not provide any information about any plans she might have to pay back taxes. (Answer; GE 2 at 24; GE 7 at 7) 2

1.d. Debt Collector – Judgment ONE ($19,789): The origin of this debt appears to be a credit card issued to Applicant on June 1, 2012, from Bank A. Applicant made her last documented payment on November 1, 2019, and ultimately the debt was charged off before being purchased by Debt Collector. Debt Collector subsequently filed suit in district court and had Applicant served with a Summons and Complaint. Applicant did not answer or appear, resulting in a finding for plaintiff on August 13, 2025, in the amount alleged in the SOR. Applicant admitted this debt in her Answer but denied having a judgment entered against her in her Questionnaire. She did, however, collectively refer to having “credit cards debt” (sic) in her Questionnaire and related having ret

FINDINGS OF FACT

salleged in the SOR. On March 23, 2026, Department Counsel submitted the Government’s written case in a File of Relevant Material (FORM). A complete copy of the FORM, consisting of Government’s Exhibits (GE) 1 to 12 and the Government’s arguments in support of the SOR, was received by the Applicant on April 9, 2026. She was afforded an opportunity to file objections and submit material to refute, extenuate, or mitigate the security concerns, but did not respond within the specified 30-day period. The case was assigned to me on June 12, 2026, and all exhibits were admitted without objection. Findings of Fact Applicant is 43 years old and has worked for a DoD contractor since 2002 as an electronic technician. Applicant completed her first application for a security clearance in connection with her present employment. She is single and has one minor child. She immigrated to the United States from Vietnam when she was 15 and was naturalized in 1998. She received an associate’s degree as an electronic technician in 2000. (GE 2 at 5, 9-10, 13, 18, 23) SOR Paragraph 1, Guideline F (Financial Considerations) The Government alleged that Applicant is ineligible for a security clearance because she has delinquent debts and unresolved tax issues, including consumer debts totaling over $182,000 and tax arrears in excess of $9,800. The following facts pertain: 1.a. Failure to File Federal Tax Returns (2021 - 2022): Applicant admitted not filing her 2021 and 2022 federal tax returns in her Answer but denied any failure to file or pay taxes in her Questionnaire. Applicant has provided no information as to why she did not file these tax returns and has not proffered a plan to handle this issue. (Answer; GE 2 at 24; GE 3 at 5; GE 7 at 5-6) 1.b. Federal Tax Debt - $9,371 (2019): Applicant admitted to these arrears in her Answer but denied any failure to file or pay taxes in her Questionnaire. She filed the federal tax return for that year but has not settled the debt. Applicant did not provide any information about any plans she might have to pay back taxes. (Answer; GE 2 at 24; GE 7 at 1) 1.c. Federal Tax Debt - $490 (2023): Applicant admitted to these arrears in her Answer but denied any failure to file or pay taxes in her Questionnaire. She filed the federal tax return for that year but has not settled the debt. Applicant did not provide any information about any plans she might have to pay back taxes. (Answer; GE 2 at 24; GE 7 at 7) 2

1.d. Debt Collector – Judgment ONE ($19,789): The origin of this debt appears to b

FINDINGS OF FACT

a credit card issued to Applicant on June 1, 2012, from Bank A. Applicant made her last documented payment on November 1, 2019, and ultimately the debt was charged off before being purchased by Debt Collector. Debt Collector subsequently filed suit in district court and had Applicant served with a Summons and Complaint. Applicant did not answer or appear, resulting in a finding for plaintiff on August 13, 2025, in the amount alleged in the SOR. Applicant admitted this debt in her Answer but denied having a judgment entered against her in her Questionnaire. She did, however, collectively refer to having “credit cards debt” (sic) in

WHOLE PERSON ANALYSIS

ined a debt consolidation service (DCS) on January 10, 2020. This debt appears on a Creditor Listing document created by the DCS, but no evidence of payment has been provided by Applicant. (Answer; GE 2 at 24-25; GE 3 at 8-9; GE 4 at 4; GE 5 at 3-4; GE 6 at 1-6; GE 8) See discussion under SOR ¶ 1.nbelow. 1.e. Debt Collector – Judgment TWO ($20,571): The origin of this debt appears to be a second credit card issued to Applicant on December 22, 2023, also from Bank A. Applicant made her last documented payment on November 1, 2019, and ultimately the debt was charged off before being purchased by the same Debt Collector. Debt Collector subsequently filed suit in district court and had Applicant served with a Summons and Complaint. Applicant did not answer or appear, resulting

POLICIES

n a finding for plaintiff on March 17, 2025, in the amount alleged in the SOR. Applicant admitted this debt in her Answer but denied having a judgment entered against her in her Questionnaire. She did, however, collectively refer to having “credit cards debt” (sic) in her Questionnaire and related having retained a DCS. This debt appears on a Creditor Listing document created by the DCS, but no evidence of payment has been provided by Applicant. (Answer; GE 2 at 24-25; GE 3 at 8-9; GE 4 at 2; GE 5 at 3-4; GE 6 at 1-6; GE 9) See di

scussion under SOR ¶ 1.m below. 1.f. Bank B – Judgment THREE ($14,469): The origin of this debt is a credit card issued to Applicant on June 25, 2002, from Bank B, account number ending in 5953. The debt was charged off at some point, whereupon Bank B filed a Writ of Execution in district court, which was granted on July 22, 2021, in the amount alleged in the SOR. The Sheriff was then ordered to satisfy the judgment out of Applicant’s personal property. Applicant admitted this debt in her Answer but denied having a judgment entered against her in her Questionnaire. She did, however, collectively refer to having “credit cards debt” (sic) in her Questionnaire and related having retained a DCS. A debt to this bank appears on a Creditor Listing document created by the DCS, but in a smaller amount ($2,026). No evidence of payment has been provided by Applicant. (Answer; GE 2 at 24-25; GE 3 at 8-9; GE 4 at 1; GE 5 at 1; GE 6 at 1-6; GE 10) See discussion under SOR ¶ 1.lbelow. 1.g. Landlord – Judgment FOUR ($15,078): Applicant failed to vacate rented premises as required by March 1, 2024. The landlords subsequently brought suit and on March 8, 2024, were awarded the amount alleged in the SOR. Applicant admitted this debt in her Answer but denied having a judgment entered against her in her Questionnaire. (Answer; GE 11) 3

1.h. Department Store Credit Card – Charge Off ($16,491):

ANALYSIS

Applicant opened this line of credit on May 24, 2009. She believes most, if not all of the debt, was a cash advance and her last documented payment on the account was November 1, 2019. Applicant admitted this debt in her Answer and generally referred to credit card debts in her Questionnaire. This debt appears on a Creditor Listing document created by the DCS, but no evidence of payment has been provided by Applicant. (Answer; GE 2 at 24; GE 3 at 8; GE 4 at 1; GE 5 at 1; GE 6 at 5) 1.i. Bank C Credit Line – Charge Off ($40,638): Applicant opened this line of credit on June 12, 2019. At some point she ceased making payments and the loan was charged off by Bank C. This debt does not appear on the DCS Creditor Listing document and there is no evidence of any payments having been made or any future plans to pay. (Answer; GE 2 at 24; GE 4 at 2; GE 5 at 1) 1.j. Bank D Credit Card – Charge Off ($624): Applicant opened this line of credit on May 4, 2023. At some point she ceased making payments and the loan was charged off by Bank D. This debt does not appear on the DCS Creditor Listing document and there is no evidence of any payments having been made or of a plan to make payments in the future. (Answer; GE 2 at 24; GE 4 at 2; GE 5 at 1) 1.k. Bank A Credit Card – Charge Off ($3,709): Applicant took out this third line of credit with Bank A on December 20, 2019. At some point she ceased making payments and the loan was charged off by Bank A. This debt does not appear on the DCS Creditor Listing document and there is no evidence of any payments having been made or any plans to pay. (Answer; GE 2 at 24; GE 3 at 8; GE 4 at 2; GE 5 at 1, 6) 1.l. Bank B Credit Card – Charge Off ($10,255): Applicant has two credit cards with Bank B. The first, with an account number ending in 5953, was issued to Applicant on June 25, 2002. Per a credit report dated May 1, 2024 (GE 4), the card had a high credit line of $13,429, a balance of $10,255, and a past-due amount of $9,414. This card was charged off as bad debt. In a second credit report dated May 7, 2025 (GE 5), the amounts were reported similarly, though the past-due amount matched the balance of

$10,255. The second credit card with Bank B was opened by Appellant on December 13, 2002, and has an account number ending in 1613. In the May 1, 2024 (GE 4) credit report, this card showed a high credit line of $7,246 and a zero balance with notes indicating it was “paid / paying as agreed.” The reported status of this card was the same in the credit report dated May 7, 2025 (GE 5). There are no other entries in either credit report for Bank B. As such, I conclude SOR ¶ 1.fand SOR ¶ 1.l. allege the same debt. (Answer; GE 2 at 24; GE 3 at 8; GE 4 at 1; GE 5 at 1) 1.m. Bank A Credit Card – Charge Off ($20,650): Similarly, as with SOR ¶ 1.l. above, the credit reports, when compared to the court judgments, show this allegation to be duplicative of the debt already alleged as Judgment TWO in SOR ¶ 1.e. (GE 4 at 2, 4; GE 5 at 3-4; GE 8; GE 9) 4

1.n. Bank A Credit Card – Charge Off ($19,161): See SOR ¶ 1.mdiscussion above. This allegation is duplicative of the debt already alleged as Judgment ONE in SOR ¶ 1.d. (GE 4 at 2, 4; GE 5 at 3-4; GE 8; GE 9) 1.o. Bank E Credit Card – Collection ($780): Applicant opened this line of credit on April 22, 2024, and it was assigned to collections by April 24, 2025. Applicant admitted this debt in her Answer and generally referred to credit card debts in her Questionnaire. This debt does not appear on the DCS Creditor Listing document and there is no evidence of any payments having been made or any plans to pay. (Answer; GE 5 at 4; GE 6 at 5) SOR Paragraph 2, Guideline E (Personal Conduct) The Government alleged that Applicant is ineligible for a security clearance because she engaged in conduct that involved questionable judgment, lack of candor, dishonesty, or unwillingness to comply with rules and regulations. The following facts pertain: 2.a. False Statement ONE in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you failed to file or pay Federal, state, or other taxes when required by law or ordinance?” Applicant admitted to the allegation in her answer, but qualified her statement explaining, “I admit, but I answered no thinking I could get a refund. I wasn’t trying to mislead.” (Answer) 2.b. False Statement TWO in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you had a judgment entered against you?” Applicant admitted to the allegation in her Answer, but qualified her statement explaining, “I admit, but don’t understand what judment (sic) against me is.” (Answer) Whole Person Evidence Applicant submitted no comments or explanations in her Answer as whole person evidence in mitigation of the security concerns alleged in the SOR. The comments and explanations Applicant included in both her Questionnaire and interrogatories, however, were reviewed in their entirety. Of particular note, in her February 4, 2022, discussion with a DoD investigator, Applicant insisted her financial difficulties are almost exclusively due to her having taken out $120,000 in cash advances from various credit cards, which she then loaned to her siblings. She loaned her brother $35,000, for example, when he lost his job. She loaned $80,000 to her sister for a downpayment on a home. None of her siblings repaid the debts. She retained the services of the DCS in 2020 and averred to having a financial plan in place to have all of her debts repaid by the end of 2024. However, no evidence of any 5

debt repayments appear in the record evidence. She no longer loans money to her siblings and now lives paycheck to paycheck. (GE 3 at 7, 9) Policies When evaluating an applicant’s suitability for national security eligibility, the administrative judge must consider the adjudicative guidelines. In addition to brief introductory

ANALYSIS

4 at 1; GE 5 at 1) 1.m. Bank A Credit Card – Charge Off ($20,650): Similarly, as with SOR ¶ 1.l. above, the credit reports, when compared to the court judgments, show this allegation to be duplicative of the debt already alleged as Judgment TWO in SOR ¶ 1.e. (GE 4 at 2, 4; GE 5 at 3-4; GE 8; GE 9) 4

WHOLE PERSON CONCEPT

ordinance?” Applicant admitted to the allegation in her answer, but qualified her statement explaining, “I admit, but I answered no thinking I could get a refund. I wasn’t trying to mislead.” (Answer) 2.b. False Statement TWO in Questionnaire: On June 13, 2025, Applicant submitted her Questionnaire wherein she answered, “No,” to the question, “In the last seven (7) years have you had a judgment entered against you?” Applicant admitted to the allegation in her Answer, but qualified her statement explaining, “I admit, but don’t understand what judment (sic) against me is.” (Answer) Whole Person Evidence Applicant submitted no comments or explanations in her Answer as whole person evidence in mitigation of the security concerns alleged in the SOR. The comments and explanations Applicant included in both her Questionnaire and interrogatories, however, were reviewed in their entirety. Of particular note, in her February 4, 2022, discussion with a DoD investigator, Applicant insisted her financial difficulties are almost exclusively due to her having taken out $120,000 in cash advances from various credit cards, which she then loaned to her siblings. She loaned her brother $35,000, for example, when he lost his job. She loaned $80,000 to her sister for a downpayment on a home. None of her siblings repaid the debts. She retained the services of the DCS in 2020 and averred to having a financial plan in place to have all of her debts repaid by the end of 20

FORMAL FINDINGS

4. However, no evidence of any 5

CONCLUSION

e must consider the adjudicative guidelines. In addition to brief introductory explanations for each guideline, the adjudicative guidelines (AG) list potentially disqualifying conditions and mitigating conditions, which are to be used in evaluatin