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.
--------
Question: of the debtor. This distinction appears immaterial under the language of sec. 409.402(7), Stats. 7 In other contexts, a security interest properly perfected at one time may later become unperfected through creditor inaction. See, e.g. sec. 409.103(l)(d)l, (2)(b), (3)(e), Stats, (four month grace periods preserving perfection in collateral removed from jurisdic tion); sec. 409.403(2) (lapse of financing statements after 5 years unless continued). 8 Interestingly, the Ansley court held that a filing under "the name Ansley Farms instead of the debtor's true name — Emory Ansley — is seriously misleading, making [the]. . . security interest unperfected.. . ." Id,., 467 F.Supp. at 55. Other cases reaching similar results are In Re Wishart, 10 U.C.C. Rep. Serv. 1296 (Bankr.W.D. Mich. 1972) (<HOLDING>); In Re Brawn, 7 U.C.C. Rep. Serv. 565 (D.C. 
 Holding statements: (A) holding that the filing of notice without motion is insufficient (B) holding a filing under mccauleys reprographics and mapping insufficient to perfect a security interest in the assets of the debtor corporation (C) holding that the reservation of a claim need not name a defendant but only identify the type of claim the debtor seeks to retain (D) holding a filing under wishart equipment co insufficient to identify the debtor horace wishart (E) holding a filing under john and mayella lintz insufficient to identify the debtor corporation

Answer: holding that the filing of notice without motion is insufficient


Question: this Opinion. Accordingly, it is ORDERED that the Trustee’s Objection to the Debtor’s Claim of exemption in her Toledo, Ohio house, pursuant to 11 U.S.C. § 522(d)(1), be, and is hereby, SUSTAINED. It is FURTHER ORDERED that the Trustee’s Objection to the Debtor’s claim of exemption in past due rents, pursuant to 11 U.S.C. § 522(d)(5), be, and is hereby, DISMISSED without prejudice. 1 . As a resident of Michigan, the Debtor along with her bankruptcy petition also filed a contemporaneous motion for a change of venue to the Northern District of Ohio, Western Division, which this Court granted. 2 . Pursuant to § 522(b), a debtor's right to claim an exemption in bankruptcy is determined by the state in which the debtor is domiciled. See In re Vaughan, 188 B.R. 234, 237 (Bankr.E.D.K.y.1995) (<HOLDING>). Some states like Michigan permit their 
 Holding statements: (A) holding that spouse could not claim exemption in property that was only property of other spouses estate (B) holding that the terms residence and domicile are not the same thing but that a debtor may only claim an exemption in property where he is domiciled (C) holding that a bankruptcy debtor may claim the homestead exemption for real property transferred to a selfsettled revocable trust even though the settlor and the beneficiary as well as the bankruptcy debtor were the same person (D) holding that the objector must not only show that the facts do not support the exemption but must also prove that the debtor knowingly deceived the trustee and the creditors at the time the exemption was made (E) holding despite contrary authority that husband debtor with a mere possessoiy interest was not entitled to claim a homestead exemption and stating it is a fundamental tenet of the law of exemptions that the debtor must have an ownership interest in the property before an exemption may be claimed a long line of illinois cases has required that a debtor have title or some ownership interest in property in order to claim a homestead exemption other courts deciding the issue under the federal exemption scheme have held that the key word is interest and that an interest in real property up to a specified amount implies a monetary interest more than just one spouses right to reside with the other

Answer: holding that spouse could not claim exemption in property that was only property of other spouses estate


Question: that Chapter Thirteen plans may “modify the rights of holders of secured claims, other than a claim secured only by a security interest in real property that is the debtor’s principal residence.” 11 U.S.C. § 1322(b)(2) (emphasis added). Defendants concede that plaintiffs’ claims are secured by liens on their principal residences. Therefore, the key issue is whether those hens constitute “security interests” for purposes of the antimodification provision of § 1322(b)(2). The ich.1992) (finding antimodification provision of § 1322(b)(2) inapplicable because creditor’s interest in the principal residence of the debtor was a “hen,” rather than a “security interest,” based on the fact that it arose nonconsensually under state tax act); In re Venable, 48 B.R. 853, 856 (S.D.N.Y. 1985) (<HOLDING>); In re Mitchell, 39 B.R. 696, 700 
 Holding statements: (A) holding that  1322b2 prohibits modification of the interest rate on the loan on the debtors principal residence (B) holding that citys tax hen on debtors principal residence was modifiable despite  1322b2 because not consensual and thus not a security interest (C) holding that the determination of whether the debtor is using real property as his principal residence is made as of the petition date for the purposes of section 1322b2 (D) holding alternatively that rights of undersecured claimant could be modified notwithstanding  1322b2 because mortgagees security interest which attached to appliances machinery furniture and equipment whether fixtures or not was not secured only by a security interest in real property (E) holding modifiable a mechanics hen on debtors principal residence because it was a statutory hen

Answer:
holding that  1322b2 prohibits modification of the interest rate on the loan on the debtors principal residence