On December 9, 2025, the Federal Trade Commission (FTC) announced it had sent warning letters to 13 property management software providers across the country, addressing concerns about accurate disclosures of pricing information for rental housing. The letters continue a trend of FTC attention to price transparency in residential rentals.
Are the FTC warning letters a sign of continued focus on pricing disclosures in the rental housing market?
Yes. The warning letters follow on the heels of multimillion-dollar consent orders with a major property management company and the country’s largest landlord of single-family homes involving pricing disclosures. The FTC sent warning letters to 13 unnamed companies that provide property management software to landlords and property management companies. The FTC letters warn recipients that they may be violating the law and state that “[a]vailable information suggests that property management software providers are limiting the ability of rental property managers and owners to accurately advertise the total monthly rental price, inclusive of all mandatory fees.” The FTC noted that it was concerned that the software programs may be restricting the ability of property owners and managers to aggregate mandatory fees and convey accurate cost information to consumers on third-party listing sites.
What are potential FTC penalties for failure to adequately disclose pricing up front?
The FTC believes this conduct constitutes unfair or deceptive acts or practices, as well as a violation of the Gramm–Leach–Bliley Act. The FTC warned that this conduct could result in federal court injunctions and civil penalties of up to $53,088 per violation.
What should affected companies do to comply with FTC disclosure requirements?
The warning letters encourage the recipients to “conduct a comprehensive review of your practices,” including website hosting platforms, software, and coding, to ensure that companies “do not impede the ability of property owners and managers to provide consumers with transparent rental prices.” All companies that advertise, or assist in advertising, rental housing should evaluate their systems to determine if they clearly disclose all mandatory fees as part of advertised rental prices. Landlords and property management companies should also evaluate their own listings and advertisements to determine if the price being advertised accurately reflects all mandatory fees.
If you have any questions, or would like additional information, please contact one of the attorneys on our Consumer Protection/FTC team.
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