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59 commenced before the bankruptcy filing or to recover a claim against the debtor that arose prepetition; (ii) the execution and levy against the debtor or its property of a prepetition judgment; (iii) any action designed to obtain possession of or exercise control over property of the estate 25 ; (iv) the creation, perfection or enforcement of liens against property of the estate; (v) the creation, perfection or enforcement of liens against property of the debtor to the extent that such liens secure a prepetition claim; (vi) the collection, assessment, or recovery of a prepetition claim against the debtor, including any informal collection procedures, such as harassing phone calls or letters; (vii) any right to setoff a prepetition debt owing to the debtor against any claim against the debtor; and (viii) the commencement or continuation of proceedings in the United States Tax Court concerning a corporate debtor's tax liability for a taxable period which the bankruptcy court may determine, or the tax liability of an individual debtor for a taxable period ending before the entry of the order for relief. One important caveat to the foregoing prohibited activities, however, is that financial institutions are permitted to place 25 The Supreme Court in City of Chicago, Illinois v. Fulton recently resolved a Circuit Court split and ruled that Section 362(a)(3) does not require a non- debtor to return a debtor's property that the non-debtor is in possession of following the filing of a bankruptcy petition. City of Chicago, Illinois v. Fulton, 141 S. Ct. 585, 592, 208 L. Ed. 2d 384 (2021) ("We hold only that mere retention of estate property after the filing of a bankruptcy petition does not violate § 362(a)(3) of the Bankruptcy Code.").

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