Hotels have gotten around this by using the term Destination Fee instead of Resort Fee. In either case, any mandatory hotel-imposed fee is a slimy business practice. It's an indication that the hotel should be avoided.

A bigger issue of "Hotel vs Resort" under the old Rewards program was the exclusion of Resorts from the lounge/breakfast benefit at the five brands that otherwise provided it to qualified elite guests. That's been mitigated to a large extent under the new Loyalty Program.