RUBEN PALAZZO v. BAYVIEW LOAN SERVICING, LLC, now known as Community Loan Servicing LLC; MANUFACTURERS AND TRADERS TRUST COMPANY, d/b/a M&T Bank
The Fourth Circuit affirmed summary judgment for mortgage servicers, holding that monthly statements, payoff requests, and tax forms sent during a debtor's Chapter 13 bankruptcy were purely informational and did not constitute prohibited debt collection. The court reasoned that explicit disclaimers clarifying the documents' non-collection purpose prevented them from violating the automatic stay or the Fair Debt Collection Practices Act.