In most jurisdictions, a creditor is not permitted to charge a repossession fee if a debtor voluntarily surrenders a vehicle. Voluntary surrender occurs when a debtor, without being compelled to do so, relinquishes possession of the vehicle to the creditor. For example, if a borrower calls the lender and asks if they can voluntarily turn in their vehicle because they can no longer afford the payments, that would likely be considered a voluntary surrender.
On the other hand, if the debtor does not voluntarily surrender the vehicle, the creditor may be able to charge a repossession fee. This may include the cost of physically removing the vehicle from the debtor's property, as well as any associated storage and administrative costs.