In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

types of property which do not pass to the trustee under Section 70 of the Act. See, Comment, The Growth of Procedural Due Process into a New Substance: An Expanding Protection for Personal Liberty and a “Specialized Type of Property” ... in our Economic System, 66 N.W.U.L.Rev. 502, 525-532 (1971); Sniadach v. Family Finance Corp., supra, 395 U.S. at 340, 89 S.Ct. 1820; Lines v. Frederick, supra, 400 U.S. at 19, 91 S.Ct. 113. The Supreme Court has recently held, in what is a logical corollary to the notion of specialized property, that at times a trustee has too tenuous a relationship to a given claim to have standing to assert that claim on behalf of the bankrupt estate. See Caplin v. Marine Midland Grace Co. of New York, 406 U.S. 416, 92 S.Ct. 1678, 32 L.Ed.2d 195 (1972) (<HOLDING>). In view of these evolving federal policies of 
 Holding statements: (A) holding that the indenture trustee has a separate contractual claim for its fees and expenses (B) holding that the relevant indenture agreement allowed the trustee to bring tort and fraud claims on behalf of the bondholders (C) holding that a chapter 7 trustee was the only person with authority to bring  a cause of action after the appointment of a trustee (D) holding that a trustee does not have standing to sue a thirdparty on behalf of debenture holders (E) holding that a trustee in a proceeding under chapter x of the bankruptcy act did not have standing to assert on behalf of the holders of debentures issued by the bankrupt in reorganization various negligence claims against an indenture trustee
holding that the indenture trustee has a separate contractual claim for its fees and expenses

options,” including by streamlining communication between the distressed borrower and foreclosing party. See Assemb. B. 278, 2011-2012 Leg., Reg. Sess. (Cal. 2012); S.B. 900, 2011-2012 Leg., Reg. Sess. (Cal. 2012). There has been a wave of litigation in state and federal courts challenging various aspects of the MERS System. Almost all of the relevant law is state rather than federal. The results under state law have been inconsistent. See Weber, supra, at 246-56 (cataloguing the “schizophrenic position of state courts” on issues relating to the MERS System). Some state supreme courts have upheld the MERS System on issues ranging from foreclosure authority to recording requirements. See, e.g., Renshaw v. Mortg. Elec. Registration Sys., Inc., 155 Idaho 656, 315 P.3d 844, 846-47 (2013) (<HOLDING>); Jackson v. Mortg. Elec. Registration Sys., 
 Holding statements: (A) holding that mers lacked standing to foreclose as the lenders nominee (B) holding that because mers receives no payments on the debt it is not the beneficiary even though it is so designated in the deed of trust (C) holding that mers is an ineligible beneficiary within the terms of the washington deed of trust act if it never held the promissory note or other debt instrument secured by the deed of trust and that characterizing mers as the beneficiary has the capacity to deceive and may give rise to an action under the consumer protection act (D) holding that mers may be a beneficiary as nominee for the lender that assignments of the deed of trust between mers members need not be recorded that mers was not liable to the borrower in negligence and that the idaho consumer protection act did not provide a cause of action to the borrower (E) holding that mers was not the beneficiary of a deed of trust under the oregon trust deed act absent conveyance to mers of the beneficial right to repayment and that mers could not hold or transfer legal title to the deed as the lenders nominee
holding that mers lacked standing to foreclose as the lenders nominee

the protection of [a lesser standard of review] but are subject to de novo review.” In re Kretzinger, 103 F.3d 943, 946 (10th Cir.1996) (quotation omitted); see also Brue v. Gonzales, 464 F.3d 1227, 1232 (10th Cir.2006) (discussing vs., 470 F.3d 509, 513-14 (2d Cir.2006) (finding legal error when “[a]lthough the BIA cited the proper legal standard at the outset of its decision, it failed to apply this deferential standard of review when evaluating the IJ’s credibility finding”). B Under 8 C.F.R. § 1003.1(d)(3)©, the BIA cannot “engage in de novo review of findings of fact determined by an [IJ].” Instead, the BIA reviews those facts found by the IJ — including credibility determinations — only to determine whether they are clearly erroneous. Id.; see also RamirezPeyro, 477 F.3d at 641 (<HOLDING>). “A finding is ‘clearly erroneous’ when 
 Holding statements: (A) recognizing that factual findings were clearly erroneous where the record before the court was simply devoid of any basis for the district courts conclusion (B) holding that the lower court is the factfinding body and that its findings of fact will not be set aside on appellate review unless they are clearly erroneous (C) holding that appellate court must defer to all implied factual findings supported by record (D) recognizing that the bia must defer to the factual findings of the ij unless they are clearly erroneous (E) holding that this court will only set aside district courts factual findings when they are clearly erroneous

recognizing that factual findings were clearly erroneous where the record before the court was simply devoid of any basis for the district courts conclusion