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ISCR Case 25-00811 · CASE

ISCR Case 25-00811denied

Case Headnote

ISCR Case No. 25-00811

deniedApr 17, 2026· Hon. Mark Harvey· hearing

Synopsis

The applicant, a 36-year-old business development coordination manager, faced security clearance denial under Guideline F due to unresolved financial issues, including a charged-off vehicle loan and multiple debts in collection. The judge found that the applicant's financial circumstances were not sufficiently mitigated, as she disputed the legitimacy of her debts without providing adequate evidence to support her claims.

Why the Applicant Was Denied

The applicant failed to provide sufficient evidence to dispute the legitimacy of her debts.
The applicant's financial support to family members contributed to her financial instability.
The applicant did not demonstrate a clear plan to resolve her outstanding debts.

Conditions Referenced

Disqualifying

F.3raisedInability or Unwillingness to Satisfy Debts
F.1raisedA History of Not Meeting Financial Obligations

Mitigating

F.2rejectedThe Conditions That Resulted in the Financial Difficulties Were Largely Beyond the Person's ControlThe applicant's financial support to family members and disputes over debts did not sufficiently mitigate the concerns.
F.3rejectedThe Individual Has Made Good Faith Efforts to Repay Overdue CreditorsThe applicant's claims of good faith efforts were not substantiated with evidence.

Key Rule Quoted

“no one has a ‘right’ to a security clearance.”
Department of the Navy v. Egan, 484 U.S. 518, 528 (1988)

Procedural Posture

SOR issuedAug 5, 2025
Answer filedSep 15, 2025
Hearing heldFeb 10, 2026via Microsoft Teams
Decision dateApr 17, 2026

Cite For

Denial of Security Clearance Due to Unresolved Financial Obligations Under Guideline F
Insufficient Evidence to Mitigate Financial Concerns
Disputes Over Debt Legitimacy Without Supporting Documentation

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 a charged-off vehicle loan and multiple debts in collection, which raised security concerns under Guideline F. While some debts were admitted and others were disputed, the judge ultimately ruled against the applicant on the charged-off vehicle loan and a bank debt, leading to a denial of the security clearance.

1.a Applicant has a charged-off vehicle loan for about $17,039.
$17,039
Finding: Against Applicant
Type: Auto 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 a bank debt placed for collection of about $658.
$658
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: —

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a	Applicant has a charged-off vehicle loan for about $17,039. $17,039	Against Applicant	Auto Loan Debt	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.e	Applicant has a bank debt placed for collection of about $658. $658	Against Applicant	Unspecified Financial	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: Applicant for Security Clearance ) ) ) ) )

STATEMENT OF CASE

SCR Case No. 25-00811 Appearances For Government: Erin P. Thompson, Esq., Department Counsel For Applicant: Vicki S. Fuller, Esq. 04/17/2026 Decision HARVEY, Mark, Administrative Judge: Guideline F (financial considerations) security concerns are not mitigated. Eligibility for access to classified information is denied. Statement of the Case On March 12, 2024, Applicant signed an Electronic Questionnaires for Investigations Processing (e-QIP). (Government Exhibit (GE) 1) On August 5, 2025, the Defense Counterintelligence and Security Agency (DCSA) issued a statement of reasons (SOR) to Applicant 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 (Directive) (January 2, 1992), as amended; and Security Executive 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. (Hearing Exhibit (HE) 2) The SOR detailed reasons why the DCSA did not find under the Directive that

FINDINGS OF FACT

tis clearly consistent with the interests of national security to grant or continue a security clearance for Applicant and recommended referral to an administrative judge to determine whether a clearance should be granted, continued, denied, or revoked. Specifically, the SOR set forth security concerns arising under Guideline F. (HE 2) On September 15, 2025, Applicant provided her response to the SOR. On December 16, 2025, Department Counsel was ready to proceed. On December 16, 2025, the case was assigned to me.

On December 16, 2025, the Defense Office of Hearings and Appeals (DOHA) issued a notice scheduling the hearing on February 10, 2026. (HE 1) The hearing was held as scheduled using the Microsoft Teams video teleconference system. During the hearing, Department Counsel offered seven exhibits into evidence; Applicant did not provide any exhibits; there were no objections; and all proffered exhibits were admitted into evidence without objection. (Tr. 15-17; GE 1-GE 7) On February 24, 2026, DOHA received a copy of the transcript. Department Counsel provided two post- hearing exhibits; Applicant provided eight post-hearing exhibits; and all post-hearing exhibits were admitted without objection. (GE 8, GE 9; Applicant Exhibit (AE) A-AE H) The record closed on April 9, 2026. (HE 4) Some details were excluded to protect Applicant’s right to privacy. Specific information is available in the cited exhibits and transcript. Findings of Fact In Applicant’s SOR response, she admitted in part the allegations in SOR ¶¶ 1.a and 1.f, and she denied the allegations in SOR ¶¶ 1.bthrough 1.e. (HE 3) She also provided extenuating and mitigating information. Her admissions are accepted as findings of fact. Applicant is a 36-year-old business development coordination manager. (Tr. 30, 33, 72; GE 1; AE A) In August of 2015, she received an associate degree in real estate sales and management and in business administration; in December of 2015, she received a bachelor’s degree in management of technology; and in May of 2024, she was awarded a master’s degree in business administration. (Tr. 32; AE A) She plans to obtain a law degree in the future. (Tr. 32) She has experience as an auditor, financial management, and budget analyst for the federal government. (Tr. 33-34) She has never married, and she does not have any children. (Tr. 36-37) She has never served in the military. (Tr. 37) Her resume provides additional information about her background and professional experience. (AE A) Financial Considerations Applicant described some circumstances that resulted in a decrease in her available income. She provided financial support to multiple family members. (Tr. 27-28) Starting about three years ago, Applicant’s mother had two surgeries, and Applicant provided funds to her mother. (Tr. 27, 63) She also provided financial assistance to her sisters and their children. (Tr. 27) Applicant borrowed $20,000 from her mother to invest in Applicant’s patent. (Tr. 62) SOR ¶ 1.a alleges Applicant has a charged-off vehicle loan for about $17,039. Her March 26, 2025 credit bureau report (CBR) shows this charged-off debt with a balance of $17,039. (GE 3 at 2) In her March 18, 2025 response to DOHA interrogatories, Applicant said: 2

[The creditor in SOR ¶ 1.a] is reporting a charged-off balance of -$17,039.00, which is inaccurate. The negative sign indicates that this amount is owed to me not a debt I am required to pay. This constitutes false and misleading information on my credit report, which I have requested be corrected multiple limes. By continuing to report this incorrect information, [this creditor] is in violation of the Fair Debt Collection Practices Act (FDCPA), specifically 15 U.S.C. § 1692e, which prohibits debt collectors from making false or misleading representations, and 15 U.S.C. § 16921, which prohibits any unfair or unconscionable means to collect or attempt to collect a debt. I do not owe these debts, nor have I ever received any bills, statements or notifications indicating that I am responsible for such obligations. Since I have never received any

communication or validation regarding these debts, I do not acknowledge their legitimacy and dispute any claims made against me. (GE 2 at 8) Applicant’s August 28, 2024, Office of Personnel Management (OPM) summary of personal subject interview (PSI) states, “Subject said her car was repossessed (date unrecalled) and she believes it was sold for more than it was worth. She does not believe that she is liable for the amount that is reflected on the credit report, and she plans to look into it and provide documentation.” (GE 7 at 3) Her September 3, 2024, OPM summary of PSI states, “She said the original balance on the account was $46,064.00. The car was repossessed and the amount of $42,104.00 was written off. That would leave a balance of $3,960, not $17,039, which is what is listed on her credit report.” (GE 7 at 8) She did not submit a CBR that shows a balance of $3,960 as an exhibit at her hearing. At her hearing, Applicant said she was in a car accident in a different state from her state of residence with the vehicle financed by the creditor in SOR ¶ 1.a. (Tr. 23) She had a dispute with her insurance company because she believed her deductible was $800, and her insurance company believed it was $1,200. (Tr. 74) She eventually paid $1,200. (Tr. 75) The shop that was repairing her vehicle allowed someone to pick up her car without her authorization before repairs were completed. (Tr. 25, 74) She was subsequently informed that a creditor repossessed her vehicle. (Tr. 25) She expected to receive a larger reimbursement from her insurance company, and she intended to use the additional funds to pay the lienholder on her vehicle. (Tr. 25) She acknowledged she was behind on her payments, but “[n]ot enough for it to be repossessed.” (Tr. 25, 41-42) She said she was only about two months behind on her payments. (Tr. 75) Applicant contacted the seller of the vehicle, and she informed the seller that “the numbers that they had within the contract were incorrect. Instead of them subtracting the value of the trade-in and then the initial down payment, they added that amount. So it made it look like I owe money when they really kind of owe me money.” (Tr. 26) She provided a copy of the sales contract, and the contract indicates the cash price is $43,000 and the unpaid balance of the cash price at the time of purchase is $40,000. (Tr. 39; HE 2) Applicant said she believed her credit was $10,000 for her trade-in and at least $2,000 for a down payment. (Tr. 40) The purchase price, including various charges and taxes, was $46,064. (HE 2) According to the contract, her gross trade-in allowance shows $11,000 for her trade in vehicle, minus $8,586 to pay off the lien on her trade in vehicle, which left a credit of $2,413. (HE 2 at page 2 of 6) She received the credit of $2,413, 3

which was listed as a “downpayment.” Id. The contract does not reflect that she made a cash downpayment. (HE 2) The seller of the vehicle is not the same entity that held the commercial paper on her car loan. Applicant asked for several items from the seller such as a digital signature certificate, IP metadata, and time-stamped audit trail. (AE C) She asked the creditor to provide: 1. The electronic-signature audit trail and IP attribution records; 2. The [Truth in Lending Act]/Reg Z calculation worksheet used to generate finance disclosures; 3. The loan-booking ledger showing application of down payment and trade- in; [and] 4. The dealer funding packet and “contract assignment acknowledgment” showing [the creditor’s] acceptance and verification of contract accuracy. (AE C-1) Applicant did no

POLICIES

provide a citation to federal or state authority which would require the creditor or seller to provide this information, or even if required, how it would warrant rescission of her purchase contract or voiding of her unpaid payments to the creditor under the contract. Applicant listed 18 problems with her vehicle contract: 1. Down payment misapplied - added into balance instead of subtracted. 2. Bundled fees not itemized. 3. APR/finance charge discrepancy. 4. "Total of Payments" mismatch with installments. 5. Ambiguous prepayment clause. 6. Unclear assignment to [a creditor]. 7. Missing trade-in credit. 8. Incomplete execution (only initials/digital marks, no w

et-ink signature). 9. Questionable digital signatures with no audit trail. 10. Missing initials on Seller's Right to Cancel (pg. 5 of 6). 11. Payment schedule ambiguity. 12. Inconsistent or missing dates. 13. Missing dealer/creditor signature. 14. Improper formatting of required “federal box” disclosures. 15. No clear identification of original creditor. 16. Optional add-ons (GAP/service) not disclosed or itemized. 17. Missing or incomplete cancellation/rescission notices. 18. Identical digital initials suggesting dealer-applied marks. On October 6, 2025, the creditor responded to Applicant’s disputes and requests for information as follows: We contacted [the vehicle seller] about your concerns relating to your Retail Installment Sale Contract (Contract) for [the vehicle] and could not substantiate your claims. The Dealership confirmed that the deal was conducted in compliance with the Electronic Signatures in Global and National Commerce Act (E-SIGN Act), there were no errors in the Truth in Lending disclosures on the Contract and no violations of the Truth in 4

Lending Act. The finance charges, Annual Percentage Rate, and “Total of Payments” figures reconcile with the repayment schedule.

ANALYSIS

he Dealership also confirmed that the down payment and trade-in were properly credited and that there were no fees or add-ons bundled into the loan without disclosure. We have enclosed copies of your signed authorizations for the add-on products, the customer delivery receipt and the final acceptance documents for the add-on products. By signing the Contract, you confirmed that you read, understood agreed to its terms and entered into a valid legally-binding credit obligation with us. Your Contract outlines that payments of $808.94 are due on the 3rd of each month. Your Contract also explains what happens if you default. Your account [was] properly charged off on June 30, 2022, due to the account status. Because your account remained in a past-due status, we repossessed the vehicle on July 7, 2022. On August 30, 2022, we sold the vehicle at a private auction and applied the proceeds from the sale to your account balance. On O

ctober 12, 2022, we sent you the enclosed Explanation of Calculation of the Deficiency, which explained that you owed a remaining balance on your account of $17,039.36. Enclosed are copies of your payment histories for your records. (AE C-2 at .pdf page 51) Applicant’s payment history indicates she missed payments for about six months in 2022 before the creditor repossessed her vehicle. (AE C-2 at .pdf page 60) Applicant said she was “more than happy to pay whatever [she owes the creditor]. I just need us to get the amount correct on it.” (Tr. 76) She said she wrote the creditor and offered to pay the debt. (Tr. 76) She said the creditor told her to contact the dealership; however, the dealership is “just like trying to run me off.” (Tr. 76) She did not provide a copy of her offer to pay the debt as an exhibit for the record. No evidence was presented of a payment plan or any payments after the vehicle was repossessed on July 7, 2022. SOR ¶¶ 1.band 1.callege Applicant has debts placed for collection for about $2,319 and $1,114, respectively. Her March 26, 2025 CBR shows these two debts placed for collection with balances of $2,319 and $1,114. (GE 3 at 2) Applicant’s August 28, 2024, OPM summary of PSI states, “Subject does agree with [the debt in SOR ¶ 1.b] and said it is from a delinquent credit card. Subject believes this is the same account with [another creditor] that she listed on her case paperwork. Subject still has not taken action to start a payment plan because of the above-mentioned dilemma she is going through with her house and it is taking up all of her time.” (GE 7 at 4) The creditor she cited to the OPM investigator was not the original creditor listed in SOR ¶ 1.b. She said she disagreed with and disputed the debt in SOR ¶ 1.c. Id. At her hearing, Applicant said she did not recall receiving credit from these two creditors. (Tr. 43-44) She said she wrote the creditors and did not receive a response. 5

(Tr. 44) She eventually hired a credit aid company to work with the creditors on her credit report to authenticate or validate her debts. (Tr. 44) The credit aid company told her not to contact her third-party creditors. (Tr. 51-52) SOR ¶ 1.dalleges Applicant has a medical debt placed for collection for about $880. Her March 26, 2025 CBR shows this debt placed for collection with a balance of $880. (GE 3 at 2) She did not believe she owed this medical debt because she had not recently been to a hospital or seen a doctor. (Tr. 51-53) SOR ¶ 1.e alleges Applicant has a bank debt placed for collection of about $658. Her March 26, 2025 CBR shows this debt placed for collection with a balance of $658. (GE 3 at 3) She said she did not recall having an account with the creditor in SOR ¶ 1.e. (Tr. 54) In her March 12, 2024 SCA, she i ndicated she owed the original creditor $500, and she would make a payment arrangement when she obtained employment. (GE 1 at 47) At her hearing, she said if the collection agent verifies the account, she intends to pay it or resolve it. (Tr. 70) In her response to DOHA interrogatories, Applicant said the four accounts listed in SOR ¶¶ 1.bthrough 1.e above are erroneous and reflect inaccurate data pertaining to her credit reports. She said she did not have a contractual relationship with the collection agencies and did not authorize them to collect any debt or funds from her. She requested documentation showing authorization to collect, and compliance with FDCPA. She denied that she “ever received any bills, statements, or notifications indicating that I am responsible for such obligations. Since I have never received any communication or validation regarding [these accounts] I do not acknowledge their legitimacy and dispute any claims made against me.” (GE 2 at 8) SOR ¶ 1.falleges in about December of 2022, Applicant’s mortgage went to foreclosure. Her March 26, 2025 CBR shows this debt was a Farmer’s Home Administration loan and the balance is $0. (GE 3 at 3) In her March 12, 2024 SCA, Applicant said the financial issue began in December of 2022, and the “balance was paid in full according to the company’s own financial records and [an] Audit.” (GE 1 at 44) She said she filed lawsuits in several courts to resolve issues. Id. at 45. Applicant lived in her home since June of 2011. (Tr. 28) Her original mortgage was $119,000. (Tr. 59) She said, “My house was paid off. There shouldn’t have been any monthly mortgage payments to be made.” (Tr. 57-58) When she sent her payments, they did not apply them to her mortgage. (Tr. 58) Applicant’s mortgage was transferred twice to different mortgage companies. (Tr. 24) She said: I never owed anything to [the SOR ¶ 1.fcreditor, which] was not the original party. It would only be [owed to the first mortgage company]. That’s who I had the contract with. So if [the SOR ¶ 1.fcreditor] was collecting that for [first mortgage creditor], then yes. It was [$]119,000 something. I want to say $487 or something like that. (Tr. 59) 6

According to the Deed of Foreclosure, notice for a foreclosure sale was published three times in a local newspaper, and notice was sent to her residence. (GE 6) Applicant said she was out of state when the notices were issued. On November 28, 2022, an agent for a limited liability corporation (LLC) purchased Applicant’s property at auction for $175,000. (GE 6) In July of 2023, the police removed Applicant from her residence. (Tr. 18) She believed her removal was improper. (Tr. 18) She filed a police report against the company that evicted her from her residence. (Tr. 19) A U.S. district court decision noted that after Applicant defaulted on the mortgage, the assigned mortgage creditor foreclosed on the property and sold it to an LLC. (GE 8 at 4) Two months later an LLC filed an ejectment action in state court, and the judge issued a default judgment against Applicant who resided at the property. Id. The county sheriff’s department evicted Applicant from the property. Id. A state court denied Applicant’s requests for relief, and the district court dismissed her claims “because relief in the federal action would have undermined the state court’s judgment in the underlying ejectment proceeding.” Id. at 5,

WHOLE PERSON CONCEPT

7. According to the docket for the U.S. district court, there were 72 filings in the litigation, and some of the filings had multiple appendices. (GE 7) Department Counsel asked, “But it’s your contention that you owned this home outright and that it was nonetheless foreclosed upon?” And Applicant answered, “Correct, I own my house. It’s paid for. None of this should have ever went on.” (Tr. 60) Applicant said the creditor advised her that she did not owe anything on the debt. (Tr. 83) Her basis for this belief is her CBR, which shows that the balance is $0. (Tr. 83) The residence is currently vacant. (Tr. 83) Applicant believed the eviction was related to a patent she requested for a support device or pillow. (Tr. 19; AE E) She spent thousands of dollars developing and marketing her patent. (Tr. 31) This patent is for a medical device, which makes it more comfortable for a patient to sit after surgery. (Tr. 81) At the time she was evicted, she was busy seeking the patent, and she did not have the financial and time resources to ensure that she was not subject to eviction. (Tr. 20) She said someone obtained a fraudulent deed on her property. (Tr. 20) The deeds and mortgages of two properties in her subdivision list her parcel number or legal description within their documentation. (Tr. 21, 61) Applicant filed several lawsuits in state and federal courts regarding the foreclosure. (Tr. 55) At the time of her

FORMAL FINDINGS

ecurity clearance hearing, her case against the mortgage company was in litigation in a state appeals court. (Tr. 22) Applicant filed six lawsuits against the creditor that foreclosed on her residence. (Tr. 57) She has a writ of mandamus pending in state court, and a January 29, 2026 court order indicating that the respondent LLC shall file an answer within 14 days. (AE D) She explained the procedural status as follow

CONCLUSION

: The clerk [in state court] is not following her ministerial duties and docketing everything that I’m giving to her. So that’s why we’re in the Court of Civil Appeals right now. And they’re having to answer as to why they are not docketing my stuff, because I can’t move forward w