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ISCR Case 24-02235 · CASE

Case record

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

Decision Date3/30/2026
Statusdenied
LevelHEARING
TypeSTANDARD ISCR
Participants
Applicant Representation: Pro Se
Government Counsel: Cynthia Ruckno
Judge: Erin C. Hogan
Guidelines Evaluated
- FFinancial Considerations · Against Applicant
Questions about ISCR 24-02235, 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 24-02235denied

Case Headnote

ISCR Case No. 24-02235

deniedMar 30, 2026· Hon. Erin C. Hogan· hearing

Synopsis

The applicant, a 38-year-old defense contractor, sought a top-secret security clearance but was denied due to unresolved financial issues under Guideline F. Despite some recent efforts to address minor consumer debts, the applicant failed to mitigate significant delinquent student loans totaling over $64,000, which he had neglected for over 15 years. The judge found that the applicant's financial irresponsibility raised concerns about his reliability and trustworthiness.

Why the Applicant Was Denied

The applicant failed to make payments on delinquent student loans for over 15 years, raising concerns about reliability and trustworthiness.
The applicant did not demonstrate a good-faith effort to resolve his significant student loan debts.
Recent attempts to address minor consumer debts were insufficient to mitigate the overall financial concerns.

Conditions Referenced

Disqualifying

AG ¶ 19(a)appliedInability to Satisfy Debts
AG ¶ 19(c)appliedA History of Not Meeting Financial Obligations

Mitigating

AG ¶ 20(b)appliedConditions Largely Beyond the Person's ControlThe applicant faced financial difficulties due to family obligations and a recent separation.
AG ¶ 20(d)rejectedGood-faith Effort to Repay Overdue CreditorsThe applicant's efforts to resolve debts were made after the hearing and were insufficient for the significant student loan debts.

Key Rule Quoted

“Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the adjudicative guidelines.”

Procedural Posture

SOR issuedMar 6, 2025
Answer filedJul 8, 2025
Hearing heldFeb 4, 2026via video-teleconference
Decision dateMar 30, 2026

Cite For

Failure to Mitigate Significant Financial Obligations Under Guideline F
Impact of Long-term Financial Irresponsibility on Security Clearance Eligibility
Consideration of Family Obligations in Financial Assessments for Security Clearance

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 significant financial issues, including over $64,000 in unresolved student loan debt and several delinquent consumer debts. Despite some recent efforts to address these debts, the applicant's long history of financial neglect led to a denial of security clearance.

1.a Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.b Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.c Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.d Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.e Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.f Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.g Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.h Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.i Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.j Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733.
$64,733
Finding: Against Applicant
Type: Student Loan Debt
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.k Applicant has a $726 credit card debt that was placed for collection.
$726
Finding: Against Applicant
Type: Credit Card Debt
Response: Denied
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.l Applicant has a $527 delinquent insurance bill that was charged off.
$527
Finding: Against Applicant
Type: Unspecified Financial
Response: Denied
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.m Applicant has a $282 delinquent internet or cell phone account that was placed for collection.
$282
Finding: Against Applicant
Type: Utility or Phone Debt
Response: Denied
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.n Applicant has a $170 delinquent cell phone account that was placed for collection.
$170
Finding: Against Applicant
Type: Utility or Phone Debt
Response: Denied
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	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.b	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.c	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.d	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.e	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.f	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.g	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.h	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.i	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.j	Applicant has ten delinquent student loan accounts with an approximate total balance of $64,733. $64,733	Against Applicant	Student Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.k	Applicant has a $726 credit card debt that was placed for collection. $726	Against Applicant	Credit Card Debt	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.l	Applicant has a $527 delinquent insurance bill that was charged off. $527	Against Applicant	Unspecified Financial	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.m	Applicant has a $282 delinquent internet or cell phone account that was placed for collection. $282	Against Applicant	Utility or Phone Debt	Denied	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.n	Applicant has a $170 delinquent cell phone account that was placed for collection. $170	Against Applicant	Utility or Phone Debt	Denied	(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

DECISION

______________ ______________ DEPARTMENT OF WAR DEFENSE OFFICE OF HEARINGS AND APPEALS In the matter of: ) ) ) ISCR Case No.

STATEMENT OF CASE

4-02235 ) ) Applicant for Security Clearance ) Appearances For Government: Cynthia Ruckno, Esq., Department Counsel For Applicant: Pro se 03/30/2026 Decision HOGAN, Erin C., Administrative Judge: Applicant did not mitigate the security concerns raised under Guideline F, Financial Considerations. Eligibility for access to classified information is denied. Statement of the Case On December 20, 2023, Applicant completed and signed an Electronic Questionnaires for Investigations Processing (e-QIP). (Government Exhibit (GE) 1) On March 6, 2025, the Defense Counterintelligence

FINDINGS OF FACT

and Security Agency (DCSA) issued a Statement of Reasons (SOR) to Applicant detailing security concerns under Guideline F, Financial Considerations. The action was taken under Executive Order (EO) 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; Department of Defense Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) effective on June 8, 2017. On July 8, 2025, Applicant answered the SOR and requested a hearing before an administrative judge. The case was assigned to me on December 19, 2025. On January

16, 2026, a Notice of Hearing was issued scheduling the hearing on February 4, 2026. The hearing was held as scheduled, via video-teleconference. During the hearing, the Government offered seven exhibits, which were admitted as Government Exhibits (GE) 1 – 7. Applicant testified. The record was held open until February 18, 2026, to allow Applicant to submit additional documents. He timely provided a document which was marked as Applicant Exhibit (AE) A, consisting of eight pages, and admitted without objection. The transcript (Tr.) was received on February 17, 2026. The record closed on that date. Based upon a review of the pleadings, exhibits, and testimony, eligibility for access to classified information is denied. Findings of Fact In response to the SOR, Applicant admitted the allegations in SOR ¶¶ 1.a – 1.jand denied the allegations in SOR ¶¶ 1.k – 1.n. His admissions are accepted as findings of fact. Additional findings follow. Applicant is a 38-year-old employee of a defense contractor seeking a top-secret security clearance. He has worked for his current employer since November 2022. He was granted a secret clearance in a previous position. His highest level of education is a bachelor’s degree. He has no military service. He is married but recently separated from his wife. They share joint custody of their three-year-old son. (Tr. 19-21, 31, 38; GE 1) The names of individuals, businesses, and institutions have been changed in this decision in the interests of protecting the Applicant’s privacy. More detailed information is located in the case file. Financial Considerations Applicant’s SOR alleges ten delinquent student loan accounts with an approximate total balance of $64,733. (SOR ¶¶ 1.a – 1.j: GE 3; GE 4; GE 5, GE 6; GE 7). The SOR also alleges Applicant has four delinquent consumer debts, to include: a $726 credit card debt that was placed for collection (SOR ¶ 1.k: GE 3 at 3; GE 4 at 2; GE 5 at 4; GE 6 at 2); a $527 delinquent insurance bill that was charged off (SOR ¶ 1.l: GE 3 at 3; GE 5 at 5; GE 6 at 2); a $282 delinquent internet or cell phone account that was placed for collection (SOR ¶ 1.m: GE 3 at 4; GE 5 at 5; GE 6 at 2); and a $170 delinquent cell phone account that was placed for collection (SOR ¶ 1.n: GE 4 at 2; GE 5 at 4; GE 6 at 2). The total approximate amount of the delinquent consumer debt is $1,705. On February 1, 2024, Applicant was interviewed by an investigator who was conducting his security clearance background investigation. The interviewer questioned him about his financial background. Applicant denied the debt alleged in SOR ¶ 1.k, which was a $726 credit card debt that was placed for collection. He admitted to once having this credit card but claims that it was never late or in collections. He intended to contact the creditor to inquire about the account. He also denied the debt alleged in SOR ¶ 1.l, which was a $5

ANALYSIS

POLICIES

7 debt owed to an insurance company that was placed for collection. He had an account with this insurance company several years ago but claims his account 2

was never late or placed for collection. He intended to contact the insurance company to inquire about the account. He denied the debt alleged in SOR ¶ 1.m, which was a $282 delinquent internet account that was placed for collection. He recalls having an internet account with this company when he lived with his mother. He is not aware whether the account is cancelled or if his mother still uses the account. He intended to contact the company to inquire about the account. (GE 2 at 5) The investigator questioned Applicant about his student loans which as of December 2023, were listed as “COLLECTION OR CHARGEOFF, PAYS AS AGREED, CRED COMMENTS: CURRENT.” He told him that he may have missed some payments during COVID when his hours and pay were reduced. He claimed that he was never notified that they were placed in collection. (GE 2 at 7-8) In his September 1, 2024, response to DOHA Interrogatories, Applicant was asked to explain the status of all his delinquent financial debts, which included all of the debts alleged in the SOR, to include his delinquent student loan accounts. For each debt, he was asked whether the debt was either paid or unpaid. If unpaid, he was asked whether he was making payments. He indicated that each debt was unpaid and that he was not making payments. He explained that his debts became delinquent because he became the breadwinner for his family immediately after graduating college and that taking care of his mother and younger brothers set him back financially. (GE 3) Applicant completed a personal financial statement in his response to the September 2024 interrogatories. He listed his total net monthly income as approximately $4,437. His total monthly expenses were approximately $3,525. He did not list any monthly debt payments. After his monthly expenses, he had a monthly remainder of approximately $912. (GE at 12) In response to interrogatories, dated January 10, 2025, Applicant responded “No” to a question that asked

ANALYSIS

hether he had resolved his U.S. Department of Education debts that were placed for collection. He listed the current outstanding balance as $62,483. He indicated that he was not on a payment plan or otherwise making regular payments on these accounts. He indicated the accounts were still in collection. (GE 2 at 11) Applicant provided a personal financial statement in response to the January 2025 interrogatories. His net monthly income is approximately $4,437. His monthly expenses total approximately $2,916. He did not list any debt payments. He had a net remainder each month after expenses of $1,521. (GE 2 at 13) During the hearing, Applicant testified that he graduated from college in 2010. After a six- month deferment period, he was required to start making his student loan payments. He has never made payments towards his student loans. In January 2026, he attempted to locate the creditors of his student loans, but he was unsuccessful. He testified that he lived with his mother and two younger brothers. His mother does not earn sufficient income, so he was responsible for paying some of the expenses in the home. One brother was in college and one brother suffers from a chronic disease which made it difficult for 3

him to work on a regular basis. As a result, he claims he could not afford to make payments towards his student loans. (Tr. 21-22, 28-29, 35-38) Applicant married in May 2022. He and his wife lived together in an apartment. They recently separated, and he moved back in with his mother and two younger brothers. He and his wife take turns caring for their son every other week. No legal separation agreement has been initiated. (Tr. 19, 38) After the hearing, Applicant submitted a document that addressed the debts alleged in SOR ¶¶ 1.k - 1.n. The status of the debts are: SOR ¶ 1.k: $726 delinquent credit card account placed for collection. On a date uncertain, Applicant formally disputed this debt under the Fair Credit Reporting Act (FCRA) with TransUnion. TransUnion approved the dispute with the result that they updated the information for this account. It is unclear whether the account was removed or if information was updated on the credit report. (AE A at 3) SOR ¶ 1.l: $627 insurance debt placed for collection. On a date uncertain, Applicant formally disputed this debt under the FCRA with TransUnion. Transunion investigated the dispute and deleted the debt from the credit report. (AE A at 4) SOR ¶ 1.m: $282 internet or cell phone account that was placed for collection. Applicant entered into a settlement agreement with the current agency collecting this account on February 26, 2026. He agreed to make two payments of $84.89 to settle the account for the total amount of $169.78. The first payment was made on February 26, 2026, and the last payment is due on March 26, 2026. (AE A at 8) SOR ¶ 1.n: $170 cell phone account that was placed for collection. While the paperwork is unclear, it appears that Applicant entered into a repayment agreement with the collection agency collecting on this debt, where he agrees to pay $42.65 a month on the 5th of each month, starting on April 5th and ending on June 5th. He provided proof that he paid $42.65 on February 26, 2026. (AE A at 5-7) As of the close of the record, no information was provided regarding steps taken to resolve the delinquent student loan debts alleged in SOR ¶¶ 1.a – 1.j. Applicant’s oldest brother testified on his behalf. He is a federal government contractor and has a security clearance at the level of top secret/sensitive compartmented information (TS/SCI). He is married. He and his wife recently purchased a home. He testified that when everyone lived at home, they all contributed to the monthly expenses and helped around the house. His mother works a low-paying job. After he moved out of the house, Applicant had to contribute more because their two younger brothers were unemployed. He confirmed that one brother was in college, and the other brother did not work full-time. Applicant currently lives in the family home. He makes the most money, so he contributes more to the household expenses. His oldest brother testified that Applicant 4

loves his country and is not a threat to national security. He has debts and is actively trying to get his financial situation in order. (Tr. 13-17) Policies The U.S. Supreme Court has recognized the substantial discretion of the Executive Branch in regulating access to information pertaining to national security emphasizing, “no one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 U.S. 518, 528 (1988). As Commander in Chief, the President has the authority to control access to information bearing on national security

WHOLE PERSON CONCEPT

nd to determine whether an individual is sufficiently trustworthy to have access to such information. Id. at 527. The President has authorized the Secretary of Defense or his designee to grant applicants eligibility for access to classified information “only 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. 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 information. 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 § 7. Thus, a decision to deny a security clearance should not be construed to suggest

FORMAL FINDINGS

that it is based, in whole or in part, on any express or implied determination about an applicant’s allegiance, loyalty, or patriotism. It is merely an indication the applicant has not met the strict guidelines the President, Secretary of Defense, and Director of National Intelligence have established for issuing a clearance. Initially, the Government must establish, by substantial evidence, conditions in the personal or professional history of the applicant th

CONCLUSION

tmay disqualify the applicant from being eligible for access to classified information. The Government has the burden of establishing controverted facts alleged in the SOR. 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 guid