Tesla does this to protect itself from being forced to use the ESA to cover things that frankly shouldn't be covered - a/k/a insurance fraud. If you think that Tesla's out to do something else nefarious to its customers, then I won't be able to talk to you - sorry.
I agree that $100 for transfer seems excessive, but it's not like it's some nefarious revenue scheme.
No, that is not true.
The ESA has conditions where they can protect themselves from insurance fraud, regardless of whether the first owner or the 20th owner tries to perpetrate the fraud.
So there is NO reason to require an approval for the transfer based on that concern.
No one else does.
Glad you agree that $100 is excessive - but asking for that is of course a revenue scheme - or are they giving that money to charity. LOL.