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.

argument, and we decline to address it further. IX. Attachment of Loan Proceeds Jeff also argues that the writ of attachment erred by stating that it applied to money that the Crider Entities might loan to him in the future. He asserts that any loan proceeds he might receive are not subject to garnishment or attachment because he must pay back such funds and, therefore, such funds are the property of the lender, not him. We disagree. Indiana’s statute listing property exempt from garnishment and attachment does not include loan proceeds as being exempt. See I.C. § 34-55-10-2. In fact, there is a federal statute that expressly exempts federal student loan proceeds from garnishment and attachment. See Brindle v. Arata, 940 N.E.2d 320, 322 (Ind.Ct.App.2010) (citing 20 U.S.C. § 1095a(d)) (<HOLDING>). Such a statute would seem to be unnecessary 
 Holding statements: (A) holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate (B) holding that the entirety of litigation settlement proceeds was taxable income to client not net after payment of attorney fees (C) holding that proceeds of a personal injury settlement are not exempt under missouri law (D) holding student loan proceeds did not lose exempt status after excess of proceeds after payment of tuition and fees was deposited in students bank account (E) holding payment in kind contracts are proceeds

(D)