Read the following excerpt from a US court opinion:
```
in the form of a guaranteed minimum benefit. See IRS Rev. Rul. 2008-7, at 12 (“Ordinarily, a period of zero annual rate of accrual followed by a period of positive annual rates of accrual would result in a plan failing to satisfy the 133 1/3% rule. However, because there is no ongoing accrual under the pre-conversion formula for these participants for service after the January 1, 2002 effective date of the conversion amendment, the lump sum-based benefit formula is the only formula under the plan ... and, pursuant to the special rule of § 411 (b)( 1 )(B)(i), that formula is treated as if it were in effect for all other plan years.”). 19 . Again, although not binding, Revenue Ruling 2008-7 supports this interpretation of the statute and regulations. See IRS Rev. Rul. 2008-7, at 10-12 , 18-19 (noting that if the applicable interest
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that new rule applied purely prospectively primarily because of reliance factor
B. recognizing district court application of the same rule
C. recognizing rule
D. holding interest rate and conversion factor for future years constant in application of 13313 rule and applying the rule only prospectively
E. holding that reasonable reliance upon the old rule is an important factor supporting prospective application of the new rule
Reply with [A, B, C, D, E] only.