The Clearing House Association, along with other trade associations, sent a letter to the FDIC to comment on an NPR relating to section 210(c)(16) of the orderly liquidation authority provisions of Dodd-Frank. In addition to commending the FDIC for providing much-needed clarifications of certain terms used in section 210(c)(16) and embracing the spirit of the statute, the letter suggests that the proposed rule should be revised (i) to clarify that authority under section 210(c)(16) cannot be exercised to enforce contracts upon a default by a subsidiary or affiliate of the covered company itself, (ii) to require that adequate protection be provided when enforcing "naked" cross-defaults (contracts that are linked to, but not supported by, the CFC), (iii) to preserve the right of a counterparty to call for margin based on the changed credit quality of affiliates of the other party to the contract, and (iv) to clarify the definitions of adequate protection and indubitable equivalent.