Can Extremal Black Holes Have Non-Zero Entropy ?

We give several pieces of evidence to show that extremal black holes cannot be obtained as limits of non-extremal black holes. We review arguments in the literature showing that the entropy of extremal black holes is zero, while that of near-extremal ones obey the Bekenstein-Hawking formula. However, from the counting of degeneracy of quantum (BPS) states of string theory the entropy of extremal stringy black holes obeys the area law. An attempt is made to reconcile these arguments.