Originally Posted by
rsteinmetz70112
Not sure all of the DOT guidance refers only to reservations without qualification.
The problem is that technically, miles have no value. So a "refund" doesn't make much sense.
Although, actually, you could probably argue that they would have to refund the fuel surcharge (which is cash) if not the points.
However, collecting money on behalf of someone (acting as a middleman) and then keeping it when they return it is outright theft.