You should probably read the link below.  Just for fun I have copied a pretty important section when it comes to refunds.

When You Must Cancel an Order

You must cancel an order and provide a prompt refund when:
•the customer exercises any option to cancel before you ship the merchandise;
•the customer does not respond to your first notice of a definite revised shipment date of 30 days or less and you have not shipped the merchandise or received the customer’s consent to a further delay by the definite revised shipment date;
•the customer does not respond to your notice of a definite revised shipment date of more than 30 days (or your notice that you are unable to provide a definite revised shipment date) and you have not shipped the merchandise within 30 days of the original shipment date;
•the customer consents to a definite delay and you have not shipped or obtained the customer’s consent to any additional delay by the shipment time the customer consented to;
•you have not shipped or provided the required delay or renewed option notices on time; or
•you determine that you will never be able to ship the merchandise.


http://business.ftc.gov/documents/bus02-business-guide-mail-and-telephone-order-merchandise-rule

Taking pre-order full payment for a product not yet delivered falls into different category than product already shipped.  While it may be perfectly legal to offer a no refund policy on items shipped/received (aside from defects/warranty issues), it certainly appears that not allowing a full refund before shipping a product is not acceptable to the FTC.

If I was BFL I would not want lawyers looking into this stuff