Yes I agree, because you are refinancing that loan.
Now - whether you call it a Loophole or just strictly playing by the rules, IMO - - if you make an additional loan for the additional funds (rather than refinancing and adding money) you have a New Loan and can charge the admin fee.
Also, we have not pointed out in this thread that if the loan is over $1,000 the fee is capped at $25 & for loans under $1,000 the fee is capped at $20. = = = Per 342.201 (f)
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My opinions are just that, and might be worth what you paid for them.