Read the following excerpt from a US court opinion:
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According to the court, the requirement that ERISA plans be maintained in writing precludes oral modifications of such plans, and the doctrine of estoppel cannot be used to alter this result. Id. Further, the court explained that ERISA requires that each plan shall “ ‘provide a procedure for amending such a plan, and for identifying the persons who have authority to amend the plan.’” Id. (quoting 29 U.S.C. § 1102(b)(3)). The court stated that by explicitly requiring that each plan specify the amendment procedures, Congress rejected the use of informal written agreements to modify an ERISA plan. Id. (citation omitted); see also Adams v. Thiokol Corp., 231 F.3d 837, 843 (11th Cir.2000) (citing Nachwalter); Smith v. Nat’l Credit Union Admin. Bd., 36 F.3d 1077, 1081 (11th Cir.1994)  (emphasis in original). Nevertheless, a
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What is the most suitable continuation to the opinion? Your options are:
A. holding that any modification or amendment to an erisa plan can be supplemented or ap plied only after the amendment has been appropriately adopted in a formal complete and written form
B. holding that the eighth amendment applies only after the state has secured a formal adjudication of guilt in accordance with the due process of law
C. holding public had fair notice of adopted zoning amendment where uses permitted in adopted amendment were a subset of those permitted in the proposed amendment
D. holding that the fourteenth amendment incorporated the sixth amendment right to counsel
E. holding the sixth amendment applicable to the states through the fourteenth amendment
Reply with [A, B, C, D, E] only.