Help With SOR Appeal

Hey Guys,

First off thanks for any help in advance. I know this will be a little long, but I want to be able to get the best advice possible.

I received my Security Clearance with the D.O.D (Army) In 2009, I got out of the Army in 2012 and proceeded on with civilian/college life. To make a long story short and to state the obvious transitioning was very hard mentally and financially. I was barely making any money and going to school full time, so needless to say my main priority was keeping the wife and kid fed and sheltered. That being said my finances and credit went downhill fast. I had my credit cards go to collections, one of our cars repossed, student loans go past due and other loans all go past due. Well fast forward until end of 2015 beginning of 2016. I got a job as a Department of Energy contactor doing D&D at a old nuclear facility. Since technically my D.O.D clearance was still active, they transferred to the DOE equivalent of a “L” clearance. Starting pay was not all that great but I knew it could be eventually. So I started paying off some of my smaller collections and unfortunately hired Lexington Law to help clean up my credit report. In Sept. of 2016 I had a QNSP with a question that asked if I had any delinquencies or collections, I answered “No”, assuming they meant new collections since they had already done a background investigation and had a credit report from 2015. All was going great, then in July of 2018 I had a ESI. I thought and still believe this was because of my upcoming 10 year mark of getting my initial clearance (Nov. 2019). The investigator asked me financial questions based off the Credit Report he had from 2015 (To which I did not know until about halfway thru the interview). Most of my collections were paid off by the time of this interview and I had not had a delinquency in a couple of years. I was only using the Credit Karma app on my phone to track my credit report, and most of the collections he was naming was not on my credit report anymore, so I told him I do not know why its on my credit or why it is in collections because I have paid them and Lexington Law was working on the credit report. I told him I knew my student loans were 120 days delinquent but have since been reconsolidated and I didn’t have an answer when he ask why I didn’t report that. I was assuming because they were at the time current. I told him I had intentions to pay off my repossed car and that $8000 was ultimately paid on the car from the high balance. I told him I was willing to pay and could afford around $60 dollars a month to help pay it down. (This comes up in the SOR but worded very different than the way I was intending on putting it to him.) So after that terrible interview I called Lexington Law to check on the status of everything and they explained to me their process and how long it takes to do everything, to which I understand and figured everything was still going good, I also asked them very specifically about the repossed car and what’s going on with it. They informed me that it was sold to a third party and there were a bunch of errors on it that needed to be disputed and starting a payment plan would “reset” my 7 year clock on it and only hurt what they were doing and to hold off. So I said ok, trusting they knew what they were doing. In October 2018 I received a LOI/PFS that I filled out and stated in the question of the car that I still had intentions to pay. I also attached a newer transunion report showing that all the collections that was asked about in the ESI was paid off. In November of 2018 I received a call from someone at the DOE asking for proof of my payment plan with the car. I said ok as I planed to talk to Lexington Law about getting something from them. They essentially told me the same thing that they already did. This was during the Government shutdown and holiday season and the DOE at our site was not working due to the shutdown, so when the Government reopened I called the investigator back and told him I assumed he was shutdown because the DOE was shutdown here I then told him what my attorney firm advised about not making a payment plan. He said ok to get a letter from my attorney stating that and pushed my deadline back to the end of January. This is where Lexington Law comes in a screws me over. Lexington Law is located in Utah, I’m in Ohio I asked for a letter stating what they advised me and they said I would have to get a letter from their “associate” Law firm in Ohio since I’m in Ohio, I called this said law firm and talked to the paralegal who told me she would tell the lawyer and have him write a letter up. So I called the investigator back and told him that. About a week passed and did not receive a message back nor a Letter stating that so I called back and actually talked to the Lawyer who was very rude and informed me “he just don’t write up letters for anything” and that he is “tired of Lexington Law” and basically told me I’m sol. So I call the Utah office and instead of giving me a letter they gave me a paper showing where they disputed the car lien holder. Since I was at my deadline date I forwarded the investigator what they gave me, to which he replied “Thanks, I’ll add it to your file.” I never heard from him or anyone in the DOE again. I did however drop Lexington Law because they were awful and use an actual law firm called White, Jacobs and Associates. I’ve used them since January of 2018 (Yes even during all my investigations) but Lexington was the ones I used to initiate it, so I used them on the questions. Then in November of 2019, my clearance was suspended as I was trying to badge in to work. Yesterday I received my SOR. The summary is as follows and It is a summary only as I am not trying to put on a public forum my SOR or notification letter. They did use Guideline E and F in 10 C.F.R as the reasons why.

  1. The “no” I put on my QNSP- I stated before why I put this.

  2. The car I said I “could” pay on, but states that I said ive “been” paying and paid off $8000 from those payment- also mentioned above the $8000 was my high balance to current balance not I paid $8000.

  3. All my collections I said I did not have (well because at the time I didn’t) He was using an old credit report and I was genially confused as to why any of that would be on my credit report, so it says he “confronted” me about debts that I owed. (Reminder: after I paid them off WJ&A and Lexington removed them from my report).

  4. The student loan ordeal (Current since 2016) but previously was 120 day delinquent. Why I didn’t list that as a delinquency.

  5. My LOI/PFS and credit report did not show payment toward the car. (all the details are above) and they said it “contradicts” my statement that I “pay” $60 a month on it. and used the $8000 as it was what I paid already, which is not true.

  6. They mention my phone call mentioning that I did not call until after the Government reopened, because I thought the DOE was shut down like it was at our site.(I’m not sure what that has to do with anything, but its in there)

I currently have a current 3-beareu credit report and a LOR from White, Jacobs, and Associates, to whom I still use, that they represent me and still work on my credit report from Jan. 2018 until now.

Again I’m sorry about the long winded story, just trying to see what the heck I can do to appeal this and what steps I should take.

First . . . They don’t care what is on your credit report. They have their own process and it often includes things not on your report because you are supposed to report ANY 60 or 120 lates from the past even if you are now current.

The good news is that many people make mistakes with these things and they are easily explained as errors as opposed to purposeful deceptions. The fact that you received crappy legal advice (credit repair and clearance requirements are often at odds) works in your favor as well.

Now that you have your SOR you need to decide how to respond. You can have a hearing in person or your can appeal on a written record. I you decide to have an in person hearing, I recommend a clearance lawyer. Not because you should need one but because you will be sitting at a table with a judge and a lawyer who represents the government. It’s not a good place to cut your teeth. If you go on the written record, a lawyer isn’t out of the question and will cost less since they only need to prepare your brief and do not need to spend a day in court.

You can usually get a consultation for free.

After this, you need to start gathering documentation for each item on the SOR. Keep this stuff in the order that they are called out in the SOR. If you have a piece of documentation or a story that applies to more than one entry, repeat it for each entry. Each argument should stand on it’s own. Each item will call out a paragraph in the Adjudicative Guidelines. Read and reread those paragraphs and mitigating factors for each. Figure out which mitigations apply to your case and build your explanation around those factors. Don’t argue mitigations that are not in the guidelines. They will fall on deaf ears.

If you are not a good writer get help.

Your first response only requires that you “admit” or “deny” each item. Most likely you are going to admit each but where they misrepresented something you may end up denying that item. Even though this is all that is required, I would prefer to document each item as fully as possible in the first response.

If you are going on the written route, you will, eventually, receive a copy of the governments brief in the case. This is where they lay out and support each item. It’s the only bite that they get at the apple. You, with their words in hand, get to have the last word. This response will be based on your first but will more seriously address the issues that they raise in their brief. This needs to be written will (it will be evaluated by a judge) and need to be organized along the lines of the government brief so that the judge doesn’t have to keep searching as he compares the two arguments.

Remember, though all of this, that they are just as concerned with where and why you got into debt as they are in what you did about it and where you are today.

None of this is easy . . . It’s not supposed to be. You don’t have a “right” to your clearance and they don’t have to prove that you are a risk. In fact, you need to prove that you are not. The need to protect classified information is always the deciding factor.

Are you currently working?

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Thanks for the response Ed, great advice and I have my work cut out for me. I am still on pay-roll by the contractor, to which I am very thankful for, but I don’t get the hours I need because I am limited to work outside the limited area, which isn’t a whole lot. Also a little on edge because all of this could be grounds for me to lose my job if the contractor don’t want to keep me in my current situation. I recently bought a house and a car for the wife and I, and finally had life straightened out when this hit me, so when you say clearance lawyers I could only imagine the money they cost, to which I don’t have due to my hours and bills, but man would I like to have one!

A point to let go – confrontation in the security interview means you were given the opportunity to volunteer information but the investigator had to bring up the information or the details.

Confrontation is not yelling or being hostile. I see too many in here key in on that phrase needlessly.

“Subject volunteered…” or “Subject clarified…” means you brought up the information to the investigator.

“Subject was notified that the following information was developed during the course of the investigation…” then "Subject provided the following information when confronted with this information. " This is confrontation.

These clarify to the adjudicator how the information was received. Volunteer is always best. Confrontation is not always bad.

These are standard phrases in the federal BI world. If the investigator asked you about debts you did not list on your SCA - that is a confrontation. If you bring up unlisted debts when asked if there are any changes to your financial response - that is volunteered.

Even if volunteered, you may be “confronted” if your volunteered information is not exactly what we have in our possession. This is to clarify the information and normally helps the Subject.

As for your SOR - Ed’s advice was sound. Take out the emotion. Treat this like you are having to explain something to your Army commander. Be accurate, be brief, be clear, be focused. Leave the accusations out as this will only reflect poorly on you. The appeals process is your last chance to provide mitigating factors - not new issues.

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