Read the following excerpt from a US court opinion:
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Ins. Co., 255 A.D.2d 644, 679 N.Y.S.2d 749 (1998) (insurance agent listed parking lot owner as an additional insured on certificate of insurance on policy purchased by snow removal subcontractor; although insurance agent stated it was "routine procedure” to send a copy of certificates to the insurance company, coverage was not amended to add parking lot owner to policy); Zurich Ins. Co. v. White, 221 A.D.2d 700, 633 N.Y.S.2d 415 (1995) (insurance agent issued certificate of insurance to state department of transportation certifying that there were no deductibles to coverage provided to painting contractor for the state; insurance company later asserted a $500 per claim deductible for property damage claims caused by pain 43 Ill.App.3d 624, 2 Ill.Dec. 148, 357 N.E.2d 125 (1976) . A similar situation occurs in the context of
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What is the most suitable continuation to the opinion? Your options are:
A. holding that exclusions are invalid unless they are communicated to the certificate holder in writing
B. holding that because exclusion was not provided to certificate holder terms of the certificate controlled
C. holding that insurance certificate holder could not maintain negligence action against insurer when certificate holder was not insurers customer did not discuss insurance coverage with insurer and did not make any specific request to procure insurance coverage
D. holding that an insurance company that does not deliver a policy to a certificate holder is estopped from asserting exclusions contained in the policy but not revealed in the certificate
E. holding that the certificate of purchase is not a claim because it does not represent a right to payment
Reply with [A, B, C, D, E] only.