If you pull up a copy of the SF-86 online you may be surprised when you read the fine print and it says, “If you have a security freeze on your consumer or credit report file, then we may not be able to complete your investigation, which can adversely affect your eligibility for a national security position.” That language is in direct contrast with the Federal Investigations Notice from October 2018 which noted that subjects do not need to unfreeze their credit reports as a part of the security clearance background investigations process.
You are likely not surprised to find out that government security clearance policies are not a source of frequent change. The process needed to make any change to the SF-86 is tedious. And that means any changes require some kind of executive branch or congressional action. In the case of accessing credit reports, the policy update resulted in a change to the Fair Credit Reporting Act which allows the government to access credit information as a part of employment or background investigations decisions. The change didn’t require any updates to the SF-86 – which is good, because updates to the SF-86 don’t happen very often.
The current version of the SF-86 is dated 2016. Changes have been made to options and questions on the eQIP or online application for security clearances, but the paper version you see in circulation is still dated 2016, and still includes that language about unfreezing credit reports – even though that isn’t required. Prior to the 2016 update, the version of the SF-86 that was used was from 2010.
Credit Freezes and Continuous Vetting
A key reason behind the 2018 FIN was to provide the means for the government to provide continuous vetting of cleared professionals. Because financial issues are one of the top causes of clearance denial and financial problems are a key risk factor in blackmail and espionage cases, being able to continually monitor credit is important to the success of CV. If the government couldn’t access credit records for individuals who had taken the personal safety step of freezing their credit reports, there would be a big gap in the success of the CV program. With 100% of all DoD clearance holders enrolled in CV, and full implementation on the horizon, the 2018 update to the FIS is a key stepping stone in helping Trusted Workforce 2.0 take shape.
When In Doubt, Ask Your Security Officer
Your security officer should be able to clarify questions you have in completing the SF-86, including any disparities between the paper version and what you may fill out online. But if your security officer directs you to unfreeze your credit report, clarity that the FIN and current clearance policies clearly state that isn’t necessary. There is certainly a chance your employer may ask you to unfreeze your credit report for some other reason – but a requirement for the security clearance process shouldn’t be one of them.
