It sounds like that's only the case for "good-will refunds" where the airline wasn't otherwise obligated to pay the refund. > Frontier said it had issued about

It sounds like that's only the case for "good-will refunds" where the airline wasn't otherwise obligated to pay the refund. > Frontier said it had issued about $100 million in what it described as “good-will refunds” that were not legally required. The airline will pay only $1 million of the $2.2 million fine because the Transportation Department credited it for providing refunds to passengers who canceled nonrefundable tickets early in the pandemic. But, either way, the DOT's main focus is on getting people the refunds. I added a bit more context to my first message to clarify that, but also the fact that the fine is ~1% of the owed refunds makes it fairly clear IMO.