If the failure of any given party to uphold any given settlement places any organization at risk, then it is incumbent to evaluate and scrutinize the settlement itself. With that, I appreciate the opportunity for you to peruse through my comment regarding this rule. Allow me to be as brief as possible. This is an OUTRAGEOUS rule and an egregious rule at that. In fact, it calls into question the most basic tenet of a settlement. For example, say an election occurs, and a group of individuals vote for a variety of candidates. Among the pool, two candidates stand out. One wins the election by several votes. In such a case, and while basic, that person wins the election. But what of the other candidates? Did they lose? In fact, there are checks in place to recount the ballots to ensure the integrity of the election itself. Albeit, while a simple and concise example, it calls into question the premise of an outcome. In fact, elections are one of the most basic elements of settlements because there are two parties involved. On one side are the candidates, and the other, the voters. The voters then exact a vote to create a settlement. At the end, there is an outcome. What this rule does is negate the outcome of the vote and thus generates the easily understood lack of trust of the election itself. While it may not be in the best interest of the OCC, the product itself is at the core of the issue, not the settlement! Such a rule will create distrust. Now, in the interest of brevity, we must take a moment to understand what is at stake. Simply, any given "person" or "group" can make a foolish bet without consequence. But, there is also a much larger unintended consequence. What will likely happen if a trade is "upside-down" is that the foolish bet not only continues on, but is doubled-down ad infinitum. Some will say, "no, that can be regulated." This is not true. Many cases take years to build, even then, the fine is fractions of a penny to the dollar. If the need to further articulate all that is wrong with this rule is merited then the hallmark root of capitalism is no longer. A trade is a deal, it is a position, it has deadlines, and if the OCC in their opinion believes they may succumb to financial risk, then the issue is the product itself and is an exposition that the regulatory body is incapable of enacting and enforcing their own rules. This is not a rule as much as it is a "there is no alternative" action. Why should an individual not pay their mortgage or other bills and obligations if such payment puts themselves in financial risk? I urge you to reconsider this rule, and ask that this rule NOT be added! Thank you for your time. Sincerely, Ted H Budzinski