Which of the Following Statements Is False

Which of the following statements is false?

A) If an attachment occurs,there is a valid security interest between the debtor and the creditor.
B) Perfection is required to protect the security interest against the claims of third parties.
C) Some third parties have preference over the holders of perfected security interests.
D) Some security interests are automatically perfected.
E) There must always be a written agreement for attachment.