ISCR Case No. 25-01228

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__ DEFENSE LEGAL SERVICES AGENCY DEFENSE OFFICE OF HEARINGS AND APPEALS In the matter of: Applicant for Security Clearance ) ) ) ) ) ISCR Case No. 25-01228 Appearances

For Government: Tovah A. Minster, Esq., Department Counsel For Applicant: Pro se 08/26/2026 Decision LAFAYE, Gatha, Administrative Judge: Applicant did not provide sufficient evidence to mitigate security concerns raised under Guideline F (financial considerations). Eligibility for access to classified information is denied. Statement of the Case Applicant submitted a security clearance application (SCA) on August 6, 2024. On February 5, 2026, the Defense Counterintelligence and Security Agency (DCSA) issued a Statement of Reasons (SOR) alleging security concerns under Guideline F. Applicant answered the SOR (Answer) on May 7, 2026, provided documentary evidence in support of her case, and elected to have her case d

cided on the written record in lieu of a hearing. The case was assigned to me on August 11, 2026. The Government’s written case was submitted on June 18, 2026. A complete copy of the file of relevant material (FORM) was provided to Applicant, who was given an opportunity to file objections and submit material to refute, extenuate, or mitigate the security concerns. Applicant

received the FORM on June 29, 2026; and she did not submit a response or provide additional documentary evidence. 1

Evidence Government Exhibit (GE) 1 and GE 2 include the SOR and Applicant’s Answer (with documentary evidence), which are already part of the administrative record. GE 3 through GE 8 are admitted in evidence without objection. Applicant’s documentary evidence in GE 2, which is embedded within her Answer, is simply referred to as her Answer in this decision. Findings of Fact The SOR alleges seven delinquent debts totaling about $50,000. In her Answer, Applicant admitted five of the debts alleged in SOR ¶¶ 1.a – 1.e and denied the debts alleged in SOR ¶¶ 1.f – 1.g. Her admissions are incorporated in my findings of fact, and after thorough review of the pleadings and evidence in this case, I make the following additional findings of fact. Applicant, age 31, has worked as an information technology (IT) professional for a Department of Defense (DOD) contractor since M

ay 2024. She has held a security clearance since 2016. She previously worked as an IT professional for another DOD contractor from 2023 to 2024 but left the position when the federal contract was not renewed. She earned her high school diploma in 2013 and attended college for one semester in 2013; and has not yet completed a degree. She is unmarried and has a six- year-old child. (GE 3, 4) Applicant completed her current SCA in August 2024. She did not list any delinquent debts in Section 26 (financial record) of the SCA because she said she rushed to complete the form. (GE 4 at 6) She discussed her financial situation in detail with a DOD investigator during her October 2024 background interview. She told the investigator she went through a period of financial hardship during the COVID-19 pandemic, and that she also became a single mother during this period. (GE 3, 4) Applicant was unable to recall specific dates of employment with her various DOD or federal contractors and her background interview also lacked clarity in this area. It is clear from the record, however, that Applicant’s work as an entry-level IT professional required her to change jobs often, about every 12 to 24 months, because of frequent changes and adjustments made to DOD or federal IT contracts. The record shows that Applicant has worked for 12 DOD or federal contractors since she started her career as an IT professional in 2016. She was dismissed for u

specified IT performance issues in 2021 and 2022 but has otherwise performed satisfactorily in all other jobs. No information was provided about Applicant’s IT technical education and on-the-job training. (GE 3-4) The allegations in SOR ¶¶ 1.a – 1.g are supported by Applicant’s statements and admissions in her Answer, background interviews, and four credit bureau reports from 2023 to 2025. (GE 3 - 8) The facts and circumstances of each debt alleged in the SOR are discussed below: 2

SOR ¶ 1.a ($23,369) alleges a delinquent debt on a joint account opened in 2018. Applicant co-signed a loan for a 2012 car with her father. During her background interview, she said she did not immediately know what the debt was for. After looking into the matter, she contacted the creditor, made payment arrangements on the debt, and provided proof of a $200 payment on the debt in May 2026. (GE 4, 7, 8) SOR ¶ 1.b ($12,004) alleges a delinquent debt for a car loan opened in 2023. Applicant said she became delinquent on payments and the creditor repossessed and sold the car, which left a remaining balance. The record shows she disputed the debt through the credit bureau but no rationale for the dispute was provided. In late 2025, she established a payment plan with the creditor and provided proof of the plan. It appear

she made one $330 payment between late 2025 and early 2026, which reduced the balance to $11,674. She accepted another offer from the creditor in April 2026, which included paying $550 in April 2026, and $318 monthly for 34 months to fully pay the debt. (GE 2 at 3-4). In her Answer, she said the delinquency resulted during a period of financial hardship. (Answer, GE 6 – 8) SOR ¶¶ 1.c ($216) and 1.d ($943) allege two delinquent debts on accounts opened in 2024 and 2021, respectively. Applicant submitted evidence that she paid a debt to the same creditor in SOR ¶ 1.c, but the account number on the debt (#7566429870001) differs from the account number on the paid receipt (#556-272-262-0001). (GE 5 at 2; GE 2 at 5) For SOR ¶ 1.d, she submitted evidence she communicated with the creditor to establish payment arrangements, which the creditor confirmed in a May 2026 response. No proof of a finalized payment plan was presented for SOR ¶ 1.d. Neither debt appears in the latest credit bureau report, from April 2025. (Answer; GE 4 - 8) SOR ¶ 1.e ($11,690) alleges a delinquent debt on an individual account for an apartment leased in 2022. Applicant leased the apartment and resided there with her boyfriend at the time, who was also her child’s father. She moved out and stopped paying rent. Her boyfriend remained in the apartment and did not pay rent. The record shows she disputed the debt through the credit bureau but no rationale for the dispute was provided. In her Answer, she stated she was “financially responsible for a family member’s living arrangement in my name.” She submitted evidence that she established a payment plan in May 2026 and pays $50 to $100 per month on the debt, and that direct debits are being made from her bank account. (Answer; GE 4 - 7) SOR ¶ 1.f ($1,639) alleges a delinquent debt on a medical account opened in 2023, which Applicant denied. She said she was unable to find a bill for the alleged debt, which did not have an accurate name, and had no information about the creditor. The debt appears in an April 2024 credit bureau report (GE 6). It does not appear in credit bureau reports from August 2024 and April 2025. (Answer; GE 7 - 8) SOR ¶ 1.g ($569) alleges a delinquent debt on an account opened in 2016, which Applicant denied. She said she contacted the creditor who informed her the account was closed and deleted seven years prior. The debt appears in the 2023 credit bureau report. It does not appear in the three credit bureau reports in 2024 and 2025. (GE 5 – 8) 3

Applicant attributed her financial situation to being a single mother and reductions in her pay. She said her bills are paid on time, unless stated otherwise. During her background interview with a DOD investigator, she voluntarily disclosed that she has fallen behind on her rent. She worked out a solution with the rental company to pay rent on a month-to-month payment schedule and the solution has worked as planned. (GE 6) Applicant admitted she made financial mistakes when she was younger, but indicated she learned from her mistakes and said she is now capable of meeting her financial obligations. She said she has no other financial issues or problems, there are no debts tied to events beyond her control, she lives within her means, and no one would question her ability to repay her debts. Though she has not had financial counseling, she said she planned and took action to pay her delinquent debts and asserted her commitment to doing so. (GE 6 at 6 -9) Policies This case is adjudicated under Executive Order (EO) 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; DOD Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG), which became effective on June 8, 2017. When evaluating an applicant’s suitability for a security clearance, the administrative judge must consider the adjudicative guidelines. 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 eligibility for access to classified information. 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 the adjudicative process. The administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. According to AG ¶ 2(c), 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 secu

ity eligibility will be resolved in favor of the national security.” Under Directive ¶ E3.1.14, the Government must present evidence to establish controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, the applicant is responsible for presenting “witnesses and other evidence to rebut, explain, extenuate, or mitigate facts admitted by the applicant or proven by Department Counsel.” The applicant has the ultimate burden of persuasion to obtain a favorable security decision. 4

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 access to classified information. Decisions include, by necessity,

onsideration 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 of potential, rather than actual, risk of compromise of classified information. Section 7 of EO 10865 provides that adverse decisions shall be “in terms of the national interes

and shall in no sense 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: Fin