ISCR Case No. 25-01310

FOR APPLICANT Pro se The Department of Defense (DoD) declined to grant Applicant a security clearance. On October 10, 2025, 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 July 2, 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. Background Applicant, in his late 30s, has been married since 2009 and has three children. He served honorably in the U.S. military from 2007 through 2013. He has taken some college courses but has not completed a degree. Applicant seeks initial national security eligibility for his employment with a government contractor, for whom he has worked since May 2019.

The SOR alleges concerns based on Applicant’s nine delinquent accounts totaling approximately $43,000. In his October 2025 response to the SOR (Answer), Applicant admitted all of the alleged debts, claimed some debt resolution efforts, and emphasized his professional accomplishments. He did not attach any documentary evidence, and he elected a decision based on the written record in lieu of a hearing. On March 24, 2026, the Government prepared a File of Relevant Material (FORM) setting forth its arguments against Applicant’s clearance eligibility and attached six exhibits. Applicant received a copy of the FORM and was given 30 days to file a response, file objections, and submit material to refute, extenuate, or mitigate the security concerns. He did not submit a response. Applicant’s delinquencies dated from late 2019, and, as noted in his Answer, his debt resolution efforts began after he initiated the clearance eligibility process and participated in his July 2025 background interview. With the exception of a consumer debt placed for collection for about $700 (SOR ¶ 1.g), all of the accounts remained unresolved as of the close of the record. Applicant did not submit any evidence to establish the timing of his debt resolution efforts. Rather, the Judge relied upon Applicant’s representations in his Answer that he had resolved SOR ¶ 1.g and was “in the process of addressing” SOR ¶ 1.h. Decision at 2. Based on the credit reports submitted by the Government, the Judge found that one vehicle loan (SOR ¶ 1.a) was being resolved through insurance. As to the remaining six accounts, Applicant expressed his intent to resolve these accounts as his finances permitted; however, he did not provide any evidence of payment plans, payments in furtherance of such plans, or a monthly budget. The Judge noted Applicant’s representations during his background interview about the circumstances contributing to his financial problems that stemmed from caring for his sister-in­ law, including his wife’s unemployment and his own significant reduction in pay to relocate to provide that care. The Judge further noted that Applicant’s period of underemployment had ended; he had been promoted; his wife had acquired gainful employment; his financial situation had stabilized; he had approximately $400 a month to address past-due debts; and his 2026 credit report reflected the current status of Applicant’s student loans, vehicle loan, and several credit card accounts. Within the Guideline F analysis, the Judge concluded that none of the mitigating conditions fully applied.1 Although he found that Applicant had established the first prong of AG ¶ 20(b), he concluded that Applicant had not established that he had acted responsibly “[g]iven his inaction.” Id. at 6. He further found that AG ¶ 20(a) did not apply due to Applicant’s inaction and continued financial delinquencies. The Judge likewise determined that AG ¶ 20(d) did not apply because Applicant had not provided evidence of a “meaningful track record” of debt reduction and because his debt resolution efforts began after the security interview. Id. at 7. The Judge concluded that Applicant had mitigated the concerns alleged at SOR ¶¶ 1.a and 1.g, and he found adversely as to the remaining seven debts. 1 AG ¶¶ 20(a): the behavior happened 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; 20(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, a death, divorce or separation, clear victimization by predatory lending practices, or identity theft), and the individual acted responsibly under the circumstances; 20(d) the individual initiated and is adhering to a good-faith effort to repay overdue creditors or otherwise resolve debts. 2

Discussion Applicant does not challenge any of the Judge’s specific findings of fact on appeal. Rather, six of the seven claims of error (Claims 1-3, 5-7) contend that the Judge afforded insufficient weight to his mitigating evidence with the Guideline F and Whole-Person analyses. The remaining claim of error, in effect, argues that the Judge reached a conclusion as to AG ¶ 20(a) that was arbitrary, capricious, or contrary to law. For the following reasons, Applicant’s arguments are not persuasive, and we affirm the Judge’s decision. Applicant avers that the Judge afforded insufficient weight to the circumstances beyond his control that contributed to his financial problems, his debt resolution efforts, the improvement to his financial situation, and his professional accomplishments. The Judge explicitly discussed all of these circumstances, explaining that the timing of and absence of a “meaningful track record” of debt repayment prevented the full application of AG ¶¶ 20(b) and 20(d). We have repeatedly held that both factors are proper for consideration within a Guideline F mitigation analysis. See ISCR Case No. 01-21386, 2003 WL 21979739 at *2 (App. Bd. Jun. 11, 2003) (a “meaningful financial track record” of resolution and repayment is necessary to establish a good-faith effort to resolve debts); ISCR Case No. 15-06440, 2017 WL 6988287 at *3 (App. Bd. Dec. 26, 2017) (timing of debt resolution efforts is relevant in evaluating the sufficiency of case in mitigation). Additionally, Applicant’s claim that the Judge found “complete inaction” by Applicant is unsupported by a review of the Decision. Appeal Brief at 3. Rather, the Judge cited Applicant’s inaction in addressing and resolving his financial delinquencies prior to his background interview, and his limited resolution efforts subsequent to the interview. In sum, Applicant’s arguments, in effect, advocate for an alternative weighing of the evidence. His disagreement with the Judge’s weighing of the evidence or his ability to argue for a different interpretation of the evidence is not sufficient to demonstrate the Judge weighed the evidence or reached conclusions in a manner that is arbitrary, capricious, or contrary to law. See ISCR Case No. 04-08975, 2006 WL 2725032 at *1 (App. Bd. Aug. 4, 2006). Applicant also challenges the Judge’s conclusion that his financial problems are “recent and ongoing” within the AG ¶ 20(a) analysis. At the close of the record, Applicant had resolved SOR ¶ 1.g, SOR ¶ 1.a was being resolved through insurance, and he was current on his student loans, a vehicle loan, and several credit card accounts. Seven delinquent accounts remained. It is well established that an applicant’s ongoing, unpaid debts evidence a continuing course of conduct and, therefore, can be viewed as recent for purposes of the Guideline F mitigating conditions. See ISCR Case No. 01-03695, 2002 WL 32114512 at *2 (App. Bd. Oct. 16, 2002). Applicant has not demonstrated that the Judge erred in his AG ¶ 20(a) analysis. Conclusion Applicant has not established that the Judge’s conclusions were arbitrary, capricious, or contrary to law. The Judge examined the relevant evidence, weighed the disqualifying and mitigating conditions, 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 3

personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). Order The decision in ISCR Case No. 25-01310 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

FOR GOVERNMENT Andrea M. Corrales, Esq., Deputy Chief Department Counsel FOR APPLICANT Pro se The Department of Defense (DoD) declined to grant Applicant a security clearance. On October 10, 2025, 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 July 2, 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. Background Applicant, in his late 30s, has been married since 2009 and has three children. He served honorably in the U.S. military from 2007 through 2013. He has taken some college courses but has not completed a degree. Applicant seeks initial national security eligibility for his employment with a government contractor, for whom he has worked since May 2019.

The SOR alleges concerns based on Applicant’s nine delinquent accounts totaling approximately $43,000. In his October 2025 response to the SOR (Answer), Applicant admitted all of the alleged debts, claimed some debt resolution efforts, and emphasized his professional accomplishments. He did not attach any documentary evidence, and he elected a decision based on the written record in lieu of a hearing. On March 24, 2026, the Government prepared a File of Relevant Material (FORM) setting forth its arguments against Applicant’s clearance eligibility and attached six exhibits. Applicant received a copy of the FORM and was given 30 days to file a response, file objections, and submit material to refute, extenuate, or mitigate the security concerns. He did not submit a response. Applicant’s delinquencies dated from late 2019, and, as noted in his Answer, his debt resolution efforts began after he initiated the clearance eligibility process and participated in his July 2025 background interview. With the exception of a consumer debt placed for collection for about $700 (SOR ¶ 1.g), all of the accounts remained unresolved as of the close of the record. Applicant did not submit any evidence to establish the timing of his debt resolution efforts. Rather, the Judge relied upon Applicant’s representations in his Answer that he had resolved SOR ¶ 1.g and was “in the process of addressing” SOR ¶ 1.h. Decision at 2. Based on the credit reports submitted by the Government, the Judge found that one vehicle loan (SOR ¶ 1.a) was being resolved through insurance. As to the remaining six accounts, Applicant expressed his intent to resolve these accounts as his finances permitted; however, he did not provide any evidence of payment plans, payments in furtherance of such plans, or a monthly budget. The Judge noted Applicant’s representations during his background interview about the circumstances contributing to his financial problems that stemmed from caring for his sister-in­ law, including his wife’s unemployment and his own significant reduction in pay to relocate to provide that care. The Judge further noted that Applicant’s period of underemployment had ended; he had been promoted; his wife had acquired gainful employment; his financial situation had stabilized; he had approximately $400 a month to address past-due debts; and his 2026 credit report reflected the current status of Applicant’s student loans, vehicle loan, and several credit card accounts. Within the Guideline F analysis, the Judge concluded that none of the mitigating conditions fully applied.1 Although he found that Applicant had established the first prong of AG ¶ 20(b), he concluded that Applicant had not established that he had acted responsibly “[g]iven his inaction.” Id. at 6. He further found that AG ¶ 20(a) did not apply due to Applicant’s inaction and continued financial delinquencies. The Judge likewise determined that AG ¶ 20(d) did not apply because Applicant had not provided evidence of a “meaningful track record” of debt reduction and because his debt resolution efforts began after the security interview. Id. at 7. The Judge concluded that Applicant had mitigated the concerns alleged at SOR ¶¶ 1.a and 1.g, and he found adversely as to the remaining seven debts. 1 AG ¶¶ 20(a): the behavior happened 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; 20(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, a death, divorce or separation, clear victimization by predatory lending practices, or identity theft), and the individual acted responsibly under the circumstances; 20(d) the individual initiated and is adhering to a good-faith effort to repay overdue creditors or otherwise resolve debts. 2

Discussion Applicant does not challenge any of the Judge’s specific findings of fact on appeal. Rather, six of the seven claims of error (Claims 1-3, 5-7) contend that the Judge afforded insufficient weight to his mitigating evidence with the Guideline F and Whole-Person analyses. The remaining claim of error, in effect, argues that the Judge reached a conclusion as to AG ¶ 20(a) that was arbitrary, capricious, or contrary to law. For the following reasons, Applicant’s arguments are not persuasive, and we affirm the Judge’s decision. Applicant avers that the Judge afforded insufficient weight to the circumstances beyond his control that contributed to his financial problems, his debt resolution efforts, the improvement to his financial situation, and his professional accomplishments. The Judge explicitly discussed all of these circumstances, explaining that the timing of and absence of a “meaningful track record” of debt repayment prevented the full application of AG ¶¶ 20(b) and 20(d). We have repeatedly held that both factors are proper for consideration within a Guideline F mitigation analysis. See ISCR Case No. 01-21386, 2003 WL 21979739 at *2 (App. Bd. Jun. 11, 2003) (a “meaningful financial track record” of resolution and repayment is necessary to establish a good-faith effort to resolve debts); ISCR Case No. 15-06440, 2017 WL 6988287 at *3 (App. Bd. Dec. 26, 2017) (timing of debt resolution efforts is relevant in evaluating the sufficiency of case in mitigation). Additionally, Applicant’s claim that the Judge found “complete inaction” by Applicant is unsupported by a review of the Decision. Appeal Brief at 3. Rather, the Judge cited Applicant’s inaction in addressing and resolving his financial delinquencies prior to his background interview, and his limited resolution efforts subsequent to the interview. In sum, Applicant’s arguments, in effect, advocate for an alternative weighing of the evidence. His disagreement with the Judge’s weighing of the evidence or his ability to argue for a different interpretation of the evidence is not sufficient to demonstrate the Judge weighed the evidence or reached conclusions in a manner that is arbitrary, capricious, or contrary to law. See ISCR Case No. 04-08975, 2006 WL 2725032 at *1 (App. Bd. Aug. 4, 2006). Applicant also challenges the Judge’s conclusion that his financial problems are “recent and ongoing” within the AG ¶ 20(a) analysis. At the close of the record, Applicant had resolved SOR ¶ 1.g, SOR ¶ 1.a was being resolved through insurance, and he was current on his student loans, a vehicle loan, and several credit card accounts. Seven delinquent accounts remained. It is well established that an applicant’s ongoing, unpaid debts evidence a continuing course of conduct and, therefore, can be viewed as recent for purposes of the Guideline F mitigating conditions. See ISCR Case No. 01-03695, 2002 WL 32114512 at *2 (App. Bd. Oct. 16, 2002). Applicant has not demonstrated that the Judge erred in his AG ¶ 20(a) analysis. Conclusion Applicant has not established that the Judge’s conclusions were arbitrary, capricious, or contrary to law. The Judge examined the relevant evidence, weighed the disqualifying and mitigating conditions, 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 3

personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). Order The decision in ISCR Case No. 25-01310 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

f 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. Background Applicant, in his late 30s, has been married since 2009 and has three children. He served honorably in the U.S. military from 2007 through 2013. He has taken some college courses but has not completed a degree. Applicant seeks initial national security eligibility for his employment with a government contractor, for whom he has worked since May 2019.

The SOR alleges concerns based on Applicant’s nine delinquent accounts totaling approximately $43,000. In his October 2025 response to the SOR (Answer), Applicant admitted all of the alleged debts, claimed some debt resolution efforts, and emphasized his professional accomplishments. He did not attach any documentary evidence, and he elected a decision based on the written record in lieu of a hearing. On March 24, 2026, the Government prepared a File of Relevant Material (FORM) setting forth its arguments against Applicant’s clearance eligibility and attached six exhibits. Applicant received a copy of the FORM and was given 30 days to file a response, file objections, and submit material to refute, extenuate, or mitigate the security concerns. He did not submit a response. Applicant’s delinquencies dated from late 2019, and, as noted in his Answer, his debt resolution efforts began after he initiated the clearance eligibility process and participated in his July 2025 background interview. With the exception of a consumer debt placed for collection for about $700 (SOR ¶ 1.g), all of the accounts remained unresolved as of the close of the record. Applicant did not submit any evidence to establish the timing of his debt resolution efforts. Rather, the Judge relied upon Applicant’s representations in his Answer that he had resolved SOR ¶ 1.g and was “in the process of addressing” SOR ¶ 1.h. Decision at 2. Based on the credit reports submitted by the Government, the Judge found that one vehicle loan (SOR ¶ 1.a) was being resolved through insurance. As to the remaining six accounts, Applicant expressed his intent to resolve these accounts as his finances permitted; however, he did not provide any evidence of payment plans, payments in furtherance of such plans, or a monthly budget. The Judge noted Applicant’s representations during his background interview about the circumstances contributing to his financial problems that stemmed from caring for his sister-in­ law, including his wife’s unemployment and his own significant reduction in pay to relocate to provide that care. The Judge further noted that Applicant’s period of underemployment had ended; he had been promoted; his wife had acquired gainful employment; his financial situation had stabilized; he had approximately $400 a month to address past-due debts; and his 2026 credit report reflected the current status of Applicant’s student loans, vehicle loan, and several credit card accounts. Within the Guideline F analysis, the Judge concluded that none of the mitigating conditions fully applied.1 Although he found that Applicant had established the first prong of AG ¶ 20(b), he concluded that Applicant had not established that he had acted responsibly “[g]iven his inaction.” Id. at 6. He further found that AG ¶ 20(a) did not apply due to Applicant’s inaction and continued financial delinquencies. The Judge likewise determined that AG ¶ 20(d) did not apply because Applicant had not provided evidence of a “meaningful track record” of debt reduction and because his debt resolution efforts began after the security interview.

Id. at 7. The Judge concluded that Applicant had mitigated the concerns alleged at SOR ¶¶ 1.a and 1.g, and he found adversely as to the remaining seven debts. 1 AG ¶¶ 20(a): the behavior happened 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; 20(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, a death, divorce or separation, clear victimization by predatory lending practices, or identity theft), and the individual acted responsibly under the circumstances; 20(d) the individual initiated and is adhering to a good-faith effort to repay overdue creditors or otherwise resolve debts. 2

Discussion Applicant does not challenge any of the Judge’s specific findings of fact on appeal. Rather, six of the seven claims of error (Claims 1-3, 5-7) contend that the Judge afforded insufficient weight to his mitigating evidence with the Guideline F and Whole-Person analyses. The remaining claim of error, in effect, argues that the Judge reached a conclusion as to AG ¶ 20(a) that was arbitrary, capricious, or contrary to law. For the following reasons, Applicant’s arguments are not persuasive, and we affirm the Judge’s decision. Applicant avers that the Judge afforded insufficient weight to the circumstances beyond his control that contributed to his financial problems, his debt resolution efforts, the improvement to his financial situation, and his professional accomplishments. The Judge explicitly discussed all of these circumstances, explaining that the timing of and absence of a “meaningful track record” of debt repayment prevented the full application of AG ¶¶ 20(b) and 20(d). We have repeatedly held that both factors are proper for consideration within a Guideline F mitigation analysis. See ISCR Case No. 01-21386, 2003 WL 21979739 at *2 (App. Bd. Jun. 11, 2003) (a “meaningful financial track record” of resolution and repayment is necessary to establish a good-faith effort to resolve debts); ISCR Case No. 15-06440, 2017 WL 6988287 at *3 (App. Bd. Dec. 26, 2017) (timing of debt resolution efforts is relevant in evaluating the sufficiency of case in mitigation). Additionally, Applicant’s claim that the Judge found “complete inaction” by Applicant is unsupported by a review of the Decision. Appeal Brief at 3. Rather, the Judge cited Applicant’s inaction in addressing and resolving his financial delinquencies prior to his background interview, and his limited resolution efforts subsequent to the interview. In sum, Applicant’s arguments, in effect, advocate for an alternative weighing of the evidence. His disagreement with the Judge’s weighing of the evidence or his ability to argue for a different interpretation of the evidence is not sufficient to demonstrate the Judge weighed the evidence or reached conclusions in a manner that is arbitrary, capricious, or contrary to law. See ISCR Case No. 04-08975, 2006 WL 2725032 at *1 (App. Bd. Aug. 4, 2006). Applicant also challenges the Judge’s conclusion that his financial problems are “recent and ongoing” within the AG ¶ 20(a) analysis. At the close of the record, Applicant had resolved SOR ¶ 1.g, SOR ¶ 1.a was being resolved through insurance, and he was current on his student loans, a vehicle loan, and several credit card accounts. Seven delinquent accounts remained. It is well established that an applicant’s ongoing, unpaid debts evidence a continuing course of conduct and

, therefore, can be viewed as recent for purposes of the Guideline F mitigating conditions. See ISCR Case No. 01-03695, 2002 WL 32114512 at *2 (App. Bd. Oct. 16, 2002). Applicant has not demonstrated that the Judge erred in his AG ¶ 20(a) analysis. Conclusion Applicant has not established that the Judge’s conclusions were arbitrary, capricious, or contrary to law. The Judge examined the relevant evidence, weighed the disqualifying and mitigating conditions, 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 secu

rity.’” Dep’t of the Navy v. Egan, 484 U.S. 518, 528 (1988). “Any doubt concerning 3

personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). Order The decision in ISCR Case No. 25-01310 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