Given the task definition and input, reply with output. 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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

would allow him to enjoy an exemption provided by 522(b)."). However, there is now agreement that the 1994 amendment to 522(f), by adding the formula set forth in 522(f)(2)(A), eliminated the need for a debtor to demonstrate the existence of equity in their property in order to avoid the fixing of a judicial lien. In re Higgins, 201 B.R. 965, 967 (9th Cir. BAP 1996). In particular, by adding the phrase, "to the extent that the sum ... exceeds the value that the debt- or's interest in the property would have in the absence of any liens," to the formula set forth in 522(f)(2)(A), it is clear that Congress intended to eliminate the need for a debtor to have equity in property in order to avoid a judicial lien. See, e.g., In re Freeman, 259 B.R. 104, 110 (Bankr.D.S.C.2001) (<HOLDING>). Bolstering this position is the amendment's
Holding statements: (A) holding that a retained equity interest is property even if it has no market value (B) holding he who seeks equity must do equity (C) holding that an action for specific performance lies in equity (D) holding that congress has made it clear in amending section 522 that a lien will be deemed to impair an exemption even when there is no equity in the property if the sum of all the liens on the property and the hypothetical value of the exemption without liens exceeds the value of the debtors interest in the property in the absence of liens (E) holding that the formula in section 522f2a creates equity for purposes of lien avoidance even if debtors otherwise have no equity in the property
(E)