Using five case reports in a short but interesting article, the authors review past comments on the importance of setting an appropriate fee. In the five cases presented, the lack of a fee became the focus of an insoluble resistance to therapy. The reasons ranged from overwhelming guilt in a patient with an obsessive character structure through patients with overt sexual identity problems who fantasized nonfinancial demands being made on them by the therapist in lieu of money. In another case, the authors felt that the nonpayment of fee was an unwitting oral gratification which would shield potentially crucial material from therapeutic inspection.