Fully mitigating financial issues is significantly more difficult for interim clearances than for final clearances.  For final clearances adjudicators consider all case information, including comprehensive investigative reports.  If a Subject Interview is conducted as part of the investigation, the report will contain detailed explanation and mitigation (and sometimes documentation) offered by an applicant.  People do a much better job of providing mitigating information when given the opportunity to tell their story face to face with an investigator, particularly if the investigator is skillful in guiding the interviewee through the process and eliciting the pertinent facts.  The investigator should be familiar with all mitigating conditions and know how to get the interviewee to address each one without asking leading questions.

For interim security clearances, government officials must rely primarily on the clearance application form and a credit report.  If an applicant completes an application and provides only the information requested on the form, the form will contain little or no mitigating information.

To have mitigating information considered for an interim clearance, the information should be entered into the “comment section” following the appropriate financial question(s) on the electronic version of the application form or at the “Continuation Space” near the end of the paper form.  Sometimes a separate statement as an attachment to the SF86 is acceptable.  The information must directly address one or more of the mitigating conditions listed under Guideline F: Financial Considerations of the Adjudicative Guidelines For Determining Eligibility For Access To Classified Information.



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William H. Henderson is a retired federal clearance investigator, President of Federal Clearance Assistance Service (FEDCAS), author of Security Clearance Manual, Issue Mitigation Handbook, and a regular contributor to ClearanceJobsBlog.com and ClearanceJobs.com.