ISCR Case No. 25-01248

tment Counsel was prepared to proceed on December 30, 2025. The case was assigned to me on

anuary 13, 2026. The Defense Office of Hearings and Appeals (DOHA) issued a Notice of Hearing on January 14, 2026. I convened the hearing as scheduled on March 25, 2026. Depa

tment Counsel offered Government Exhibits 1 through 6, which were admitted without objection.

Applicant testified on her own behalf. She asked that the record remain open until April 24, 2026, for the receipt of additional documentation. No additional documentation was received from Applicant. DOHA received the transcript of the hearing (Tr.) on April 8, 2026. The record closed on April 24, 2026. Findings of Fact Applicant is 58 years old, single, and has one child. She is a high school graduate and has taken several college courses. She has been employed by a defense contractor as a manufacturing technician since approximately January 2025. (Government Exhibit 1 at Sections 12, 17; Government Exhibit 2 at 6-7; Tr. 5- 6.) Paragraph 1 (Guideline F, Finan

ial Considerations) The Government alleges in this paragraph that Applicant is ineligible for clearance because she is financially overextended and therefore potentially unreliable, untrustworthy, or at risk of having to engage in illegal acts to generate funds. Applicant admitted all the allegations (SOR 1.a through 1.p) with explanations. Based on the available documentary evidence Applicant is alleged to owe approximately $37,950 in past-due or charged-off consumer debts. The Government provided credit reports of Applicant dated October 1, 2024; August 21, 2025; and December 22, 2025, supporting the existence of the debts. (Government Exhibits 4, 5, and 6.) The debts are also supported by her admissions to an authorized investigator from the Office of Personnel Management during an interview on December 23, 2024. (Government Exhibit 2.) The debts are also supported by her answers to interrogatories propounded to her by DCSA dated June 25, 2025. (Government Exhibit 3.) Concerning her debts Applicant testified: I incurred that debt because I overextended myself, and I did speak to the creditors. But, it wasn’t feasible because I had so many open debts. I tried to set up payment plans with them. But, they wanted a certain amount for each credit card, and I tried. I really tried to work with them. But, by the time I was making all these payments, I couldn’t pay my utilities. I was left without being able to buy food for pets and things like that. (Tr. 11.) Applicant further testified that she is working with a lawyer to file for Chapter 7 bankruptcy. This would be her second bankruptcy. She had previously filed for Chapter 7 relief in 2008. She is currently making payments to the lawyer for his fee. Once that fee is paid the bankruptcy will be finalized. (Tr. 23-25.) The current status of the debts alleged in the SOR is as follows: 2

1.a. Applicant admitted that she owes a credit card issuer $9,200 for a charged-off debt. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 26-27.) 1.b. Applicant admitted that she owes a different credit card issuer $7,131 for a charged-off debt. No recent payments have been made on t his debt, and s he has no plans to make payments. This debt is not resolved. (Tr. 27-28.) 1.c. Applicant admitted that she owes Collection Agency One $5,524 for a debt placed in collection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 28.) 1.d. Applicant admitted that she owes a bank $4,416 for a charged-off credit card debt. The most recent credit report in the record states this account is “Settled,” with the further description, “Account paid in full for less than full balance.” Based on the available evidence this debt has been resolved. This subparagraph is found for Applicant. (Government Exhibit 6 at 2; Tr. 29.) 1.e. Applicant admitted that she owes Collection Agency Two $2,448 for a debt placed in collection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 29-30.) 1.f. Applicant admitted that she owes Collection Agency Two $1,952 for a debt placed in collection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 29-30.) 1.g. Applicant admitted that she owes a

ank $1,850 for a debt placed in c ollection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 30.) 1.h. Applicant admitted that she owes Collection Agency One $1,076 for a charged-off debt. No recent payments have been made on t his debt, and s he has no plans to make payments. This debt is not resolved. (Tr. 28.) 1.i. Applicant admitted that she owes Collection Agency One $802 for a debt placed in collection by

Bank A. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 28.) 1.j. Applicant admitted that she owes Collection Agency One $802 for a debt placed in collection by

Bank B. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 28.) 1.k. Applicant admitted that she owes this creditor $644 for a charged-off debt. Applicant testified that she attempted to resolve this debt but was unsuccessful. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 30-32.) 3

1.l. Applicant admitted that she owes Collection Agency Two $622 for a debt placed in collection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 29.) 1.m. Applicant admitted that she owes this creditor $556 for a charged-off debt. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 32.) 1.n. Applicant admitted that she owes Collection Agency One $495 for a debt placed in collection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 28.) 1.o. Applicant admitted that she owes a creditor $348 for a charged-off credit card debt. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 32.) 1.p. Applicant admitted that she owes a creditor $84 for a mobile telep

one debt that has been placed for collection. No recent payments have been made on this debt, and she has no plans to make payments. This debt is not resolved. (Tr. 32-33.) Policies When evaluating an applicant’s national security eligibility for a security clearance, the administrative judge 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 evaluating an applicant’s national security eligibility. These guidelines are not inflexible rules of law. Instead, recognizing the complexities of human behavior, these guidelines are applied 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. The entire process is a conscientious scrutiny of applicable guidelines in the context 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, “Any 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. I have not drawn inferences based on mere speculation or conjecture. Directive ¶ E3.1.14, requires the Government to present evidence to establish controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, “The applicant is 4

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 seeks access to classified information enters 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 national security eligibility. Decisions include, by necessity, consi

eration 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 or sensitive information. Finally, as emphasized in Section 7 of Executive Order 10865, “Any determination under this order adverse to an applicant shall be a determination in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” See also Executive Order 12968, Section 3.1(b) (listing multiple prerequisites for access to classified or sensitive information.) Analysis Paragraph 1 (Guideline F, Financial Considerations) The security concerns relating to the guideline for financial considerations are set out in AG ¶ 18, which reads in pertinent part: Failure to live within one’s means, 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 protect classified or sensitive information. Financial distress can also be caused or exacerbated by, and thus can be a possible indicator of, other issues of personnel security concern such as excessive gambling, mental health conditions, substance misuse, or alcohol abuse or dependence. An individual who is financially overextended is at greater risk of having to engage in illegal or otherwise questionable acts to generate funds. AG ¶ 19 describes two conditions that could raise se

urity concerns and may be disqualifying in this case: (a) inability to satisfy debts; and (c) a history of not meeting financial obligations. Applicant has fifteen delinquent consumer debts totaling approximately $37,950 that she has not paid (SOR 1.a to 1.c, 1.e to 1.p). As stated above, SOR 1.d is found for 5

Applicant. AG ¶¶ 19(a) and (c) apply to the remaining debts. The burden thereby shifts to Applicant to mitigate the adverse inference of her delinquent debts. The guideline includes four conditions in AG ¶ 20 that could mitigate the security concerns arising from Applicant’s alleged financial difficulties: (a) the behavior ha

pened so long ago, was so infrequent, or occurred under such circumstances that it is unlikely to recur and does not cast doubt on the individual’s current reliability, trustworthiness, or good judgment; (b) the conditions that resulted in the financial problem were largely beyond the person’s control (e.g., loss of employment, a business downturn, unexpected medical emergency, or a death, divorce or separation, clear victimization by

predatory lending practices, or identity theft), and the individual ac