The Federal Government's new up-front "cost recovery fee" on debt agreements is likely to deliver a profit to the Insolvency and Trustee Service of Australia, while handing the triple burden of collection, administration and liability for the controversial fee over to the private sector.Debt agreement administrators are complaining that the Attorney General is not listening to their concerns about the new fee and how it is proposed it be collected. A discussion paper has been released and a consultation process is currently underway, with submissions due from industry and the public on December 8.ITSA's proposed new Debt Agreement Proposal lodgement fee (DAP fee) has now been set at A$191, after an investigation found the cost of registering and approving debt agreement proposals is $2.35 million per year.When setting the fee, for 2011, the Insolvency and Trustee Service projected that new debt agreement numbers will fall next year, to 12,300, from 13,000 in 2010, delivering exactly $2.35 million in new revenue if each debtor is charged $191.Those forecasts for new debt agreement numbers either support exactly the policy aim of cost recovery or are based on predictions that the DAP fee will reduce demand.The forecasts do not seem to account for expected interest rate rises of up to 1.25 per cent in 2011, which will add to both repayments and accumulated debts.In addition, early 2010's unusually low debt agreement numbers were affected by the economic stimulus payments from the Federal Government. These are now long gone from household accounts.And new bankruptcy laws are designed to channel more debt-stricken consumers into agreements and away from full-blown bankruptcy.The imposition of this fee works against the new bankruptcy laws, said Brody Clarke, executive director of the Debt Agreement Professionals Association."DAPA is concerned that the introduction of the fee goes beyond cost recovery policy and will only serve to discourage debtors from entering a voluntary agreement to repay their creditors. No comparative fee exists in bankruptcy for lodgement of a debtor's petition."Our other concerns are that this is counter-intuitive to the stated aim of the new laws plus and the burden of it all falls on the private operators - the debt agreement administrators."