Some filters have a "leak back" valve, so the filter doesn't empty out when the engine shuts down, I think it has mostly to do with the filter's orientation. If it's upside down for example, you really need the valve, so that the filter doesn't empty out over night. Waiting for the filter to fill up with oil is what's causing the clatter, only what I'd bet you're hearing is rod noise rather than valve clatter - which is even worse!
Most VW cars (at least they used too) require a filter with this valve for just this reason......