ISCR Case No. 26-00154

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RINGS AND APPEALS In the matter of: ) ) ) ISCR Case No. 26-00154 ) Applicant for Security Clearance ) Appearances For Government: John Renehan, Esquire, Department Counsel For Applicant: Samir Nakhleh, Esquire, Applicant’s Counsel 07/29/2026 Decision CEFOLA, Richard A., Administrative Judge: Statement of the Case On February 17, 2026, in accordance with Department of Defense (DoD) Directive 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. Applicant answered the SOR on March 22, 2026, and requested a hearing before an administrative judge. (Answer.) The case was assigned to me on April 20, 2026. The Defense Office of Hearings and Appeals (DOHA) issued a notice of hearing on April 23, 2026, scheduling the hearing for June 17, 2026. The hearing wa

convened as scheduled. The Government offered Exhibits (GXs) 1 through 5, which were admitted into evidence. Applicant testified on her own behalf. Applicant offered six documents, which I marked Applicant’s Exhibits (AppXs) A through F, and admitted into evidence. The record was left open until July 17, 2026, for receipt of additional documentation. Applicant offered

two additional documents, which

marked AppXs G and H, and admitted into evidence. DOHA received the transcript of the hearing (TR) on July 2, 2026. Findings of Fact Applicant denied all the allegations in SOR. After a thorough and careful review of the pleadings, exhibits, and testimony, I make the following findings of fact: Applicant is a 49-year-old employee of a defense contractor. She has been employed with the defense contractor since October 2023. She has held a security clearance since 2000, when Applicant joined the U.S. Army. She achieved the rank of Sergeant First Class (E-7). Applica

t was deployed five times during her 20 years of military service, twice into combat zones. She is divorced and has four minor children. Applicant attributes her past financial difficulties to funeral expenses due to her mother and grandmother dying within two weeks of each other, and to a failed rental car business. Her business partner fled to another state and took one of their three rental cars with her. (TR at page 11 line 24 to page 17 line 4, and at page 20 line 18 to page 22 line 11.) Guideline F - Financial Considerations 1.a. and 1.b. These are one and the same debt to Creditor A, the successor creditor for this auto loan, in the amount of between $14,000~$17,000. This debt has been satisfied, with “no balance due,” as evidenced by documentation from Creditor A. (TR at page 17 line 5 to page 18 line 17, at page 22 lines 12~16, at page 31 line 6 to page 33 line 17, and AppX F.) 1.c. Applicant denies the alleged past-due debt to Creditor C in the amount of about $185. It has been paid, with a “BALANCE DUE: $0.00,” as evidenced by documentation from Creditor C. (TR at page 18 line 18 to page 19 line 4, at page 29 lines 2~16, and AppX C.) 1.d. Applicant denies the alleged past-due debt to Creditor D in the amount of about $14,784. This auto loan has been settled for $9,609 and paid, as evidenced by documentation from Creditor D. (TR at page 19 line 5 to page 20 line 17, at page 22 lines 17~20, at page 33 line 19 to page 3

line 9, and AppX H.) Applicant’s current financial situation is stable. (TR at page 24 line 23 to page 26 line 15.) 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. 2

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. Under Directive ¶ E3.1.14, the Government must present evidence to establish controverted facts alleged in the SOR. Directive ¶ E3.1.15 states the “applicant is re

ponsible 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 potential, 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 se

se 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 secur

ty concern relating to the guideline for Financial Considerations is set out in AG ¶ 18: Failure to live within one's means, satisfy debts, and meet financial obligations may indicate poor self-control, lack of judgment, or unwillin