I realize we are not able to charge a fee for allowing our customers to execute a cash advance on their credit card to make a payment on their auto loan with us.

However, would Regulation Z still govern a fee charged for taking a payment by phone regardless of the medium used to produce the funds to make the actual payment?

In other words, the fee isn't assessed because it happens to be a credit card used to make a payment, the fee is assessed as a processing fee due to the extra work of taking the request by phone.

Would such a fee be allowed?

Would it be considered independent of finance charges?

If not Reg Z, would there be a different regulation that would govern such a fee?

Thanks in advance for you responses!

If you are providing additional methods for a customer to make a payment, I see nothing that would prevent you from charging a fee for using the service. For example, Chase charges you $10 if you want to make an on-line payment.