Is the relief valve a piece of metal like the clicker the nun used in class?
Pretty much what I found in the NL branded filter. But perhaps more important is where the relief is located. The job of the valve is to bypass oil around the element, if the element has too much pressure drop from clogging. The theory is it is better to have unfiltered oil than no oil.
A relief valve at the bottom, means the oil comes into the filter, washes over the dirty side of the element, then through the valve to your bearings. You are getting not just unfiltered oil, but unfiltered oil with everything the filter has caught so far mixed in. With a top relief valve, unfiltered oil enters the filter and then immediately exits via the valve, without first washing the dirty side of the element.
Properly designed and maintained, the valve really should never open, but most filters have them for a reason.