Are there any issues/concerns around charging a 'processing fee' upfront on a consumer auto loan request? More particularly if that fee is not refundable; but I'm interested in any concerns surrounding that that I should perhaps consider.
This fee is listed on our rate sheet; but does not specify if it's refundable or not; nor when it will be paid.
What if the rate sheet did not end up in the customers' hands? (I don't know if it did or didn't.)
One of my concerns is that the fee is not applied consistently. It feels like a Fair Lending concern to me. But I also feel like there are probably other concerns - for example, if it's charged up front, shouldn't it be an application fee not a processing fee?