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.

[Q]: 188 (Bkrtcy.S.D.Ohio E.D.1981); In re Davis, 16 B.R. 473 (D.Kan.1981). Or after a judgment has been entered: In re Young, 22 B.R. 620 (Bkrtcy.N.D.Ill.E.D.1982); In re Breuer, 4 B.R. 499, 6 B.C.D. 136 (Bkrtcy.S.D.N.Y.1980). (5)Courts that hold that a debtor may cure a default where a foreclosure sale has been held provided that the debtor's right of redemption under state law has not expired: In re Johnson, 29 B.R. 104 (Bkrtcy.S.D.Fla.1983); In re Chambers, 27 B.R. 687 (Bkrtcy.S.D.Fla.1983); In re Taylor, 21 B.R. 179 (Bkrtcy.W.D.Mo.1982); In re Thompson, 17 B.R. 748 (Bkrtcy.W.D.Mich.1982). 32 B.R. at 790. To the fourth group we add the following recent opinions by the Fifth and Seventh Circuits: Grubbs v. Houston First American Savings Association, 730 F.2d 236 (5th Cir.1984) (en banc) (<HOLDING>); Matter of Clark, 738 F.2d 869 (7th Cir.1984)
Holding statements: (A) holding debtor could cure default partly because the bank held a recourse loan and therefore could recover against the original borrower personally (B) holding that the debtor had the right to cure the default because the foreclosure sale was not complete under state law until it was confirmed by a court (C) holding debtor could cure after the debtor had previously made payments to the bank (D) holding that a debtor may cure a default after acceleration but expressing no limit on the right (E) holding debtor could include property because the bank accepted payments directly from the debtor and had previously allowed the debtor to cure default
[A]: holding debtor could cure default partly because the bank held a recourse loan and therefore could recover against the original borrower personally

[Q]: of the original note because the endorsement on the note in evidence did not match the endorsements on the copy of the note attached to the complaint. As argued by OneWest, the Cummings presented no testimony or evidence to contradict Mr. Den-son's testimony that the note in evidence was the original note acquired by OneWest in May 2010. Likewise, the Cummings' argument regarding the validity of the assignment of mortgage from MERS to In-dyMac is not relevant to OneWest's standing to foreclose. Because the evidence showed that OneWest possessed the original note endorsed in blank at the time it filed the complaint, its standing is established from its status as the note holder regardless of any recorded assignments. See Stone v. BankUnited, 115 So.3d 411, 413 (Fla. 2d DCA 2013) (<HOLDING>) (quoting Mazine v. M & I Bank, 67 So.3d 1129,
Holding statements: (A) holding that there is no impermissible modification of the note because the very terms of the note allow for prepayment without a penalty (B) holding that the holder of the note must act in a manner that effectively provides notice that the holder has exercised his option (C) holding that because a mortgage provides the security for the repayment of the note the person having standing to foreclose a note secured by a mortgage may be either the holder of the note or a nonholder in possession of the note who has the rights of a holder (D) holding that where a mortgagee is acting on behalf of the note holder there is no disconnection between note and mortgage and the mortgagee may foreclose (E) holding that the note and the mortgage must coexist to give the mortgage validity
[A]: holding that there is no impermissible modification of the note because the very terms of the note allow for prepayment without a penalty

[Q]: 563 U.S. 421, 438, 131 S.Ct. 1866, 179 L.Ed.2d 843 (2011). Nonetheless, the District Court and the Plan have cited to the language in the Summary Plan Description ("SPD") as the language of the Plan. We, too, adopt this approach. See US Airways, Inc. v. McCutchen, 569 U.S. 88, 133 S.Ct. 1537, 1543 n.1, 185 L.Ed.2d 654 (2013) ("Because everyone in this case has treated the language from the summary description as though it came from the plan, we do so as well."). Moreover, insofar as McLaughlin and J.J.M. now contend that the SPD was not "designated a plan document" and so cannot control here, McLaughlin Reply Br. 1, we deem this argument forfeited because it is raised solely in the reply brief. See Laborers' Int'l Union of N. Am. v. Foster Wheeler Corp., 26 F.3d 375, 398 (3d Cir. 1994) (<HOLDING>). 4 . We have considered McLaughlin's and
Holding statements: (A) holding an argument not raised in opening brief is waived (B) holding that a party waives an argument that it raises in the background section of its brief but not in the argument section (C) holding argument waived for failure to raise it in opening brief (D) holding that argument not raised in opening brief is waived (E) holding that an argument is not preserved unless a party raises it in its opening brief
[A]:
holding an argument not raised in opening brief is waived