In Corvello v. Wells Fargo Bank, N.A. (9th Cir. 2013) 728 F.3d 878, the primary issue was whether the defendant was required to offer the plaintiffs permanent loan modifications after they complied with their TPP's. The court ruled the pleading was sufficient to state a claim on that basis. (Corvello v. Wells Fargo Bank, N.A., supra, 728 F.3d at p. 885.) In Corvello the Rosenthal Act claim was a secondary issue. The court noted the defendant had acknowledged it was a debt collector as defined in the Rosenthal Act. With no analysis, the court agreed with the district court's finding the defendant "was engaged in debt collection." (Corvello v. Wells Fargo Bank, N.A., supra, 728 F.3d at p. 885.) Relying on In re Bank of America HAMP Contract Litigation, 2011 WL 2637222 and Reyes v. Wells Fargo Bank, N.A., 2011 WL 30759, it determined the "TPP was more than an informational circulation." (Corvello v. Wells Fargo Bank, NA, supra, 728 F.3d at p. 885.)