ISCR Case No. 26-00075

FOR GOVERNMENT Andrea M. Corrales, Esq., Deputy Chief Department Counsel

Pro se The Department of Defense (DoD) declined to grant Applicant a security clearance. On March 10, 2026, DoD issued a Statement of Reasons (SOR) advising Applicant of the basis of that decision – security concerns raised under Guideline F (Financial Considerations) of the National Security Adjudicative Guidelines (AG) in Appendix A of Security Executive Agent Directive 4 (effective June 8, 2017) and DoD Directive 5220.6 (Jan. 2, 1992, as amended) (Directive). On August 4, 2026, Defense Office of Hearings and Appeals Administrative Judge Charles C. Hale denied Applicant national security eligibility. Applicant appealed pursuant to Directive ¶¶ E3.1.28 and E3.1.30. Discussion The SOR alleged fifteen delinquent consumer and utility debts totaling approximately $92,000. In her answer to the SOR (Answer), Applicant admitted all allegations. The Judge

resolved three allegations favorably (SOR ¶¶ 1.d, 1.g, and 1.h)1 and twelve adversely. In concluding that Applicant failed to establish that she acted responsibly regarding her debts, the Judge cited to several factors, including evidence that emerged during the adjudicative process of Applicant’s gambling and frequent international travel. Transcript at 23–26. Additionally, the Judge characterized Applicant’s “recent remedial actions in 2025 and 2026” as being “reactive to her security clearance investigation” and quoted Appeal Board precedent holding that “the timing of debt resolution efforts is an important factor in evaluating mitigation.” Decision at 10–11. On appeal, Applicant challenges the adverse findings on the grounds that “important updated information regarding [her] financial situation was overlooked” and that “the decision was made primarily based on the information initially received, rather than on [her] current financial circumstances.” Appeal Brief at 1. She requests reconsideration “based on the most current and complete record,” including the “substantial steps” she has taken to reduce balances, enter payment arrangements, and resolve accounts. Id. As a preliminary matter, we are not authorized to reconsider a record but instead only to consider allegations of material error. Directive ¶ E3.1.32. That issue aside, to the extent that Applicant is suggesting that the Judge did not review all the evidence she submitted, we are not persuaded. First, a judge is presumed to have considered all evidence of record. Second, our review of the record and his decision convinces us that he did so. Prior to the hearing, Applicant submitted Applicant Exhibits (AE) A through J. Post-hearing, she submitted seven additional exhibits, AE K through Q. The Judge’s decision reflects his receipt, admission, and consideration of those exhibits. It is unclear whether Applicant is instead suggesting that she submitted material in addition to those exhibits. Although Applicant does not explicitly assert that she submitted more than seven exhibits post hearing, she refers to documents that are not in the record. For example, Applicant states that she provided “updated information” regarding two accounts owed to the same creditor, that the balances on those two accounts have been substantially reduced, and that the Judge’s decision does not reflect those lower balances. Appeal Brief at 2. We cannot determine to which specific debts Applicant is referring but regardless the record before us does not contain this purported “updated information.” In another example, Applicant asserts that she completely paid off the debt at SOR ¶ 1.i. and provided evidence of the same. Again, there is no such evidence in the record. Instead, the record supports the Judge’s finding that this debt was unresolved, which he based on one of Applicant’s post-hearing submissions (AE M). Decision at 6. An applicant must make a sufficient proffer to establish a basis for the Board to remand the case or take other corrective action. Applicant’s vague allusions to other documents are not sufficient to establish a prima facie showing that she submitted additional evidence that was not included in the record. E.g., ISCR Case No. 14-04959 at 2 (App. Bd. Apr. 6, 2016). In summary, Applicant has not established either that the Judge failed to consider evidence that she submitted or that she was denied the due process afforded by the Directive. 1 The formal findings reflecting favorable findings on SOR ¶¶ 1.m and 1.o are in error. The text of the decision confirms adverse findings on these two allegations. Decision at 6–7. This error is harmless, as it did not affect the outcome of the case. 2

Applicant also challenges the Judge’s findings regarding the timing of her remedial actions, in which he concluded that Applicant’s repayment efforts “were generally initiated after she completed her SCA . . . [and] the security clearance investigation process had begun.” Decision at 11. Applicant’s assertion that she was addressing her delinquent debts before she had notice that her clearance was in jeopardy is undermined by her own statement at hearing, in which she acknowledged: “I would say previously, I didn’t take items on my [credit] report serious. And if it didn’t stop me from getting something, I didn’t take it serious. . . . And I didn’t make [the payments] because I just wasn’t serious about them. But now I see that it was serious, and I need to make the payments.” Transcript at 77–78. The Judge’s findings and conclusions about the timing of Applicant’s remedial efforts are additionally supported by the Government’s credit reports and Applicant’s submissions documenting her recent efforts. Conclusion The remainder of Applicant’s brief amounts to a disagreement with the Judge’s weighing of the evidence. None of her arguments, however, are sufficient to establish that the Judge weighed the evidence in a manner that was arbitrary, capricious, or contrary to law. See ISCR Case No. 04­ 08975, 2006 WL 2725032 at *1 (App. Bd. Aug. 4, 2006). Rather, the Judge examined and weighed the disqualifying and mitigating evidence and articulated a satisfactory explanation for the decision. The record is sufficient to support that the Judge’s findings and conclusions are sustainable. “The general standard is that a clearance may be granted only when ‘clearly consistent with the interests of the national security.’” Dep’t of the Navy v. Egan, 484 U.S. 518, 528 (1988). “Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). 3

Order The decision in ISCR Case No. 26-00075 is AFFIRMED. Signed: Moira Modzelewski Moira Modzelewski Administrative Judge Chair, Appeal Board Signed: Allison Marie Allison Marie Administrative Judge Member, Appeal Board Signed: Eric H. Borgstrom Eric H. Borgstrom Administrative Judge Member, Appeal Board 4