Yes they would be.....I'm not sure where I heard that it was illegal to gain interest on that money, and I'm not sure why it would be illegal. If they are able to, I doubt that is the primary reason that they require the money up front. I'm with eel, it would present a problem for collecting that money when it comes time to pay up. As someone else said, it would help with fiscal planning as well. As for gaining interest, that would just be an added bonus. Since they are holding your money in good faith while you are left without it, and thus the interest, the practice seems a little shady, and one that might meet with some opposition if more people knew about it....That said, since the agencies need to know how many licenses are purchased and that the money is already there, they might as well gain interest on it while they have it because, afterall, they need all the money they can get. I don't have a problem paying up front, or them gaining interest on the money, so long is that money is used appropriately.