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ISCR Case ISCR Case No. 25-00870 · CASE

Case record

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

Decision Date3/24/2026
Statusgranted
LevelHEARING
TypeSTANDARD ISCR
Participants
Applicant Representation: Pro Se
Government Counsel: John Renehan
Judge: Richard A. Cefola
Guidelines Evaluated
- FFinancial Considerations · For Applicant
Questions about ISCR ISCR Case No. 25-00870, 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. 25-00870granted

Case Headnote

ISCR Case No. ISCR Case No. 25-00870

grantedMar 24, 2026· Hon. Richard A. Cefola· hearing

Synopsis

The applicant, a 46-year-old defense contractor employee with a Master's Degree, faced security concerns under Guideline F due to financial difficulties stemming from a lengthy custody battle and periods of unemployment. The judge found that the applicant had taken responsible steps to address her debts, including enrolling in a debt consolidation program and making regular payments, leading to a decision to grant her security clearance.

Why the Applicant Prevailed

The applicant demonstrated a good-faith effort to repay overdue creditors through a debt consolidation program.
The applicant's financial difficulties were largely attributed to circumstances beyond her control, such as a custody battle and unemployment.
The applicant provided evidence of making regular payments towards her debts, indicating responsible financial behavior.

Conditions Referenced

Disqualifying

AG ¶ 19(a)raisedInability to Satisfy Debts
AG ¶ 19(c)raisedHistory of Not Meeting Financial Obligations

Mitigating

AG ¶ 20(a)appliedBehavior Occurred Long Ago or Infrequently
AG ¶ 20(b)appliedConditions Largely Beyond the Person's Control
AG ¶ 20(c)appliedReceiving Financial Counseling
AG ¶ 20(d)appliedGood-faith Effort to Repay Debts
AG ¶ 20(e)appliedReasonable Basis to Dispute Debts

Key Rule Quoted

“The administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision.”

Procedural Posture

SOR issuedJul 25, 2025
Answer filedAug 8, 2025
Hearing heldFeb 18, 2026convened as scheduled
Decision dateMar 24, 2026

Cite For

Mitigation of Financial Difficulties Under Guideline F
Consideration of Circumstances Beyond an Applicant's Control in Financial Cases
Good-faith Efforts in Debt Repayment 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: granted

The judge found that the applicant had several past-due debts but successfully mitigated the financial concerns under Guideline F. The applicant demonstrated responsible behavior by making payments towards her debts and addressing her financial issues, leading to a favorable decision for her security clearance.

1.a Applicant denies the alleged past-due debt to Creditor A in the amount of $12,214. Pursuant to a court order, she is making monthly payments of $266 towards this debt, as evidenced by court documents.
$12,214
Finding: For Applicant
Type: Unspecified Financial
Response: Denied
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20):
(b) conditions largely beyond the person’s control; acted responsibly
Mitigation:
Claimed
Debt Paid in Full
1.b Applicant admits the alleged past-due debt to Creditor B in the amount of $4,751. This debt is enrolled in a debt consolidation program, and the past-due amount has been reduced to $1,142. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation.
$4,751
Finding: For Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20):
(b) conditions largely beyond the person’s control; acted responsibly
Mitigation:
Claimed
Debt Paid in Full
1.c Applicant disputed through the credit repair process the $4,419 alleged past-due debt to Creditor C. She avers, credibly, that the creditor failed to verify the debt; and as such, it was not enrolled in her debt consolidation program.
$4,419
Finding: For Applicant
Type: Unspecified Financial
Response: Unknown
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.d Applicant admits the alleged past-due debt to Creditor D in the amount of $2,759. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation.
$2,759
Finding: For Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20):
(b) conditions largely beyond the person’s control; acted responsibly
Mitigation:
Claimed
Debt Paid in Full
1.e Applicant admits the alleged past-due debt to Creditor E in the amount of $2,106. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation.
$2,106
Finding: For Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20):
(b) conditions largely beyond the person’s control; acted responsibly
Mitigation:
Claimed
Debt Paid in Full
1.f Applicant disputed, through the credit repair process, the $985 alleged past-due debt to Creditor F. She avers, credibly, that this was an invalid debt; and as such, it was not enrolled in her debt consolidation program.
$985
Finding: For Applicant
Type: Unspecified Financial
Response: Unknown
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.g Applicant admits the alleged past-due debt to Creditor G in an unspecified charged off amount. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation.
Finding: For Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20):
(b) conditions largely beyond the person’s control; acted responsibly
Mitigation:
Claimed
Debt Paid in Full

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a	Applicant denies the alleged past-due debt to Creditor A in the amount of $12,214. Pursuant to a court order, she is making monthly payments of $266 towards this debt, as evidenced by court documents. $12,214	For Applicant	Unspecified Financial	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	(b) conditions largely beyond the person’s control; acted responsibly	Claimed Debt Paid in Full
1.b	Applicant admits the alleged past-due debt to Creditor B in the amount of $4,751. This debt is enrolled in a debt consolidation program, and the past-due amount has been reduced to $1,142. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. $4,751	For Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	(b) conditions largely beyond the person’s control; acted responsibly	Claimed Debt Paid in Full
1.c	Applicant disputed through the credit repair process the $4,419 alleged past-due debt to Creditor C. She avers, credibly, that the creditor failed to verify the debt; and as such, it was not enrolled in her debt consolidation program. $4,419	For Applicant	Unspecified Financial	Unknown	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.d	Applicant admits the alleged past-due debt to Creditor D in the amount of $2,759. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. $2,759	For Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	(b) conditions largely beyond the person’s control; acted responsibly	Claimed Debt Paid in Full
1.e	Applicant admits the alleged past-due debt to Creditor E in the amount of $2,106. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. $2,106	For Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	(b) conditions largely beyond the person’s control; acted responsibly	Claimed Debt Paid in Full
1.f	Applicant disputed, through the credit repair process, the $985 alleged past-due debt to Creditor F. She avers, credibly, that this was an invalid debt; and as such, it was not enrolled in her debt consolidation program. $985	For Applicant	Unspecified Financial	Unknown	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.g	Applicant admits the alleged past-due debt to Creditor G in an unspecified charged off amount. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation.	For Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	(b) conditions largely beyond the person’s control; acted responsibly	Claimed Debt Paid in Full

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

el For Applicant: Pro se 03/24/2026 Decision CEFOLA, Richard A., Administrative Judge: Stat

STATEMENT OF CASE

Case On July 25, 2025, in accordance with Department of Defense Directive (DoD) 5220.6, as amended (Directive), the DoD issued Applicant a Statement of Reasons (SOR) alleging facts that raise security concerns under Guideline F (Financial Considerations). The SOR further informed Applicant that, based on information available to the government, DoD adjudicators could not make the preliminary affirmative finding it is clearly consistent with the national interest to grant or continue Applicant’s security clearance. 1

Applicant answe

FINDINGS OF FACT

dthe SOR on August 8, 2025, and requested a hearing before an administrative judge. (Answer.) The case was assigned to me on December 8, 2025. The Defense Office of Hearings and Appeals (DOHA) issued a notice of hearing on December 11, 2025, scheduling the hearing for February 18, 2026. The hearing was convened as scheduled. The Government offered Exhibits (GXs) 1 through 4, which were admitted into evidence. Applicant testified on her own behalf. Applicant offered five documents, which I marked Applicant’s Exhibits (AppXs) A through E and admitted into evidence. The record was left open until March 18, 2026, for receipt of additional documentation. Applicant offered AppXs F through J, in a timely fashion and they were admitted into evidence. DOHA received the transcript of the hearing (TR) on February 27, 2026. Findings of Fact Applicant admitted to the allegations in SOR ¶¶ 1.b~1.e. and 1.g. She denied SOR allegations ¶¶ 1.a and 1.f. After a thorough and careful review of the pleadings, exhibits, and testimony, I make the following findings of fact. Applicant is a 46-year-old employee of a defense contractor. She has a Master’s Degree, and has been employed with the defense contractor since July of 2024. Applicant has held a security clearance, off and on, since 1999. She is divorced and has one child. Applicant attributes her financial difficulties to periods of unemployment, but mostly to a lengthy custody battle with her former spouse. (TR at page 5 lines 10~24, and at page 14 line 19 to page 30 line 17.) Guideline F - Financial Considerations 1.a. Applicant denies the alleged past-due debt to Creditor A in the amount of $12,214. Pursuant to a court order, she is making monthly payments of $266 towards this debt, as evidenced by court documents. (TR at page 30 line 18 to page 37 line 23, Answer at page 13, and AppX G.) 1.b. Applicant admits the alleged past-due debt to Creditor B in the amount of $4,751. This debt is enrolled in a debt consolidation program, and the past-due amount has been reduced to $1,142. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. (TR at page 37 line 24 to page 38 line 25, AppX I at page 12, and AppX J.) 2

1.c. Applicant “disputed through the credit repair process” the $4,419 al leged past- due debt to Creditor C. She avers, credibly, that “the creditor failed to verify the debt;” and as such, it was not enrolled in her debt c

ANALYSIS

solidation program. (TR at page 39 lines 1~23, and AppX I at page 12.)

1.d. Applicant admits the al

leged past-due debt to Creditor D in the am

ount of $2,759. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. (TR at page 40 lines 2~11, and AppX I at page 12.) 1.e. Applicant admits the alleged past-due debt to Creditor E in the amount of $2,106. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. (TR at page 40 lines 12~23, and A ppX I at page 12.) 1.f. Applicant disputed, “through the credit repair process,” the $985 alleged past- due debt to Creditor F. She avers, credibly, that this was “an invalid debt;” and as such, it was not enrolled in her debt consolidation program. (TR at page 40 line 24 to page 41 line 10, and AppX I at page 12.) 1.g. Applicant admits the alleged past-due debt to Creditor G in an unspecified charged off amount. This debt is enrolled in her debt consolidation program. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. (TR at page 41 line 11 to page 42 line 6, and AppX I at page 12.) Policies When evaluating an applicant’s national security eligibility, 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 to be used in evaluating an applicant’s national security eligibility. These guidelines are not inflexible rules of law. Instead, recognizing the complexities of human behavior, administrative judges apply the guidelines in conjunction with the factors listed in AG ¶ 2 describing the adjudicative process. The administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. According to AG ¶ 2(a), the entire process is a conscientious scrutiny of a number of variables known as the whole-person concept. The administrative judge must consider all available, reliable information about the person, past and present, favorable and unfavorable, in making a decision. The protection of the national security is the paramount consideration. AG ¶ 2(b) requires that “[a]ny doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.” In reaching this decision, I have drawn only those conclusions that are reasonable, logical, and based on the evidence contained in the record. 3

Under Directive ¶ E3.1.14, the Government must present evidence to establish contro

POLICIES

a lengthy custody battle with her former spouse. (TR at page 5 lines 10~24, and at page 14 line 19 to page 30 line 17.) Guideline F - Financial Considerations 1.a. Applicant denies the alleged past-due debt to Creditor A in the amount of $12,214. Pursuant to a court order, she is making monthly payments of $266 towards this debt, as evidenced by court documents. (TR at page 30 line 18 to page 37 line 23, Answer at page 13, and AppX G.) 1.b. Applicant admits the alleged past-due debt to Creditor B in the amount of $4,751. This debt is enrolled in a debt consolidation program, and the past-due amount has been reduced to $1,142. She is making monthly payments of $290 to the debt consolidation program, a portion of which goes to this creditor, as evidenced by documentation. (TR at page 37 line 24 to page 38 line 25, AppX I at page 12, and AppX J.) 2

WHOLE PERSON CONCEPT

ts alleged in the SOR. Directive ¶ E3.1.15 states the “applicant is responsible for presenting witnesses and other evidence to rebut, explain, extenuate, or mitigate facts admitted by the applicant or proven by Department Counsel, and has the ultimate burden of persuasion as to obtaining a favorable clearance decision.” A person who applies for access to classified information seeks to enter 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 the applicant may deliberately or inadvertently fail to protect or safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation as to potentia

FORMAL FINDINGS

rather than actual, risk of compromise of classified information. Section 7 of Executive Order (EO) 10865 provides that adverse 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 to live within one's

CONCLUSION

ans, 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 protec