As a federally-supervised bank, I wouldn't touch this kind of fee. As a state-licensed industrial loan or thrift company, however, you won't face the troubling legal/ethical issue of requiring the public to pay for something the law grants as a right. State licensing agencies aren't going to question an act of their general assembly.
If your affiliate plans to charge this type of fee, they will have to call it a FC and include it in the APR. Since it's a one-time, up front fee, you shouldn't have trouble verifying these disclosures.