Key takeaways
- The FTC sent letters to 13 property management software companies warning against deceptive or unfair acts or practices in the marketing or advertising of residential units. The letters cautioned that concealing the full monthly cost of rental properties may violate both the FTC Act and the Gramm-Leach-Bliley Act.
- These letters follow several recent enforcement actions against major property managers, and signal broader regulatory scrutiny against platforms involved in rental pricing and marketing.
- The FTC expects listings to display the total monthly price of rental properties—including all mandatory fees—clearly and conspicuously.
- Property management software providers and their clients should consult counsel to ensure their current system configurations and pricing disclosure practices comply with these standards.
- The warning letters are part of a broader push for pricing transparency that extends beyond the rental housing market. Businesses should proactively review their pricing practices to ensure full transparency and compliance with FTC standards.
In depth
On December 9, 2025, the FTC issued warning letters to 13 property management software providers across the United States, claiming that recipients may be unlawfully hindering renters from receiving accurate monthly rental prices for properties listed on online platforms. This move follows the agency’s recent enforcement actions and reflects its broader initiative to curb anticompetitive, unfair and deceptive practices in the rental housing market.
According to the letter, the failure to provide accurate monthly rental pricing prevents consumers from meaningfully comparing alternatives and making informed decisions, which causes the market to operate inefficiently. The letter states that the FTC has information suggesting that property management software providers are failing to accurately advertise the true monthly rental price of properties on their websites.
The FTC specifically identifies concerns that property management software programs may negatively impact consumers and competition in the market when they limit property owners’ and managers’ ability to share precise cost details with consumers on third-party listing websites.
Recipients were warned that such conduct may violate Section 5 of the FTC Act, which makes it illegal to engage in unfair or deceptive acts or practices in or affecting commerce and is punishable by civil penalties and injunctions. In addition, the FTC argues that if software platforms use pricing misrepresentations to obtain consumers' financial information, they may violate the Gramm-Leach-Bliley Act, which would subject them to potential civil penalties of up to $53,088 per violation.
The letters are the latest in a series of actions focusing on pricing transparency in the rental housing sector. On December 2, 2025, the FTC secured a stipulated order enjoining Greystar from engaging in deceptive pricing practices and requiring the company to pay $23 million in fines.1 Similarly, in September 2024, the FTC settled its claims alleging that Invitation Homes engaged in deceptive pricing charged junk fees, and committed other unlawful conduct for $48 million in penalties.2 And, on November 24, 2025, the Department of Justice (DOJ) settled its antitrust case alleging that RealPage used nonpublic, competitively sensitive information shared by landlords to systematically increase rental prices.3
These developments are consistent with a broader enforcement effort to prioritize price transparency to ensure consumers are provided with accurate information in order to make informed decisions. This includes the joint complaint by the FTC and Maryland Attorney General to stop Lindsey Auto from falsely advertising low prices and overcharging consumers with unwanted fees.4 Another example is the FTC's new rule targeting "junk fees" in the live entertainment ticketing and short-term lodging industries.5
Next Steps
To ensure compliance and avoid enforcement actions, companies who list, manage, or advertise rental housing practices should:
- Assess how prices are displayed to consumers. Algorithms, software or coding controlling the flow of information to online listings, and website hosting platforms all may contribute to whether accurate pricing information is given to consumers. It is paramount that all mandatory fees are shown to consumers upfront, and fully transparent.
- Inform and train employees and third-party providers. If pricing transparency issues are found, personnel must be instructed to make the relevant changes to the underlying website, data flow, or software. Ensuring that employees and third parties are aware of legal requirements and instructing them on how to comply can mitigate against enforcement pitfalls.
- Contact counsel. Companies should contact counsel familiar with the relevant legal frameworks and various government agencies to review, design and tailor compliance programs that align with pricing strategies, proactively mitigating the risk of enforcement actions.
Conclusion
The FTC's and DOJ's efforts show that price transparency is a priority, and that pricing practices in the rental housing market may continue to receive heightened scrutiny moving forward. By targeting property management software providers, the FTC signals concern that certain software configurations may facilitate deceptive practices by limiting full price disclosures. This concern is not limited to the rental housing sector; thus, stakeholders in other industries should proactively review their pricing configurations as well. Given the government's willingness to pursue both monetary penalties and injunctive relief, these developments should be treated as a signal to implement robust compliance measures around pricing and advertising practices.
1 Greystar Agrees to Pay $24 Million and Stop Deceptive Advertising Practices as a Result of FTC and Colorado Lawsuit Alleging the Firm Deceived Consumers About Rent Prices | Federal Trade Commission
2 FTC Takes Action Against Invitation Homes for Deceiving Renters, Charging Junk Fees, Withholding Security Deposits, and Employing Unfair Eviction Practices | Federal Trade Commission
3 Office of Public Affairs | Justice Department Requires RealPage to End the Sharing of Competitively Sensitive Information and Alignment of Pricing Among Competitors | United States Department of Justice
4 https://urldefense.com/v3/__https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-maryland-attorney-general-act-stop-lindsay-auto-falsely-touting-low-prices-overcharging__;!!Hj9Y_P0nvg!SYbSK-AWIGHgXowWdXZWPhpbgBiSGk3_cErKMLkuna5guKBl0JD2xt5LvgmvMGE2m9X3rZMSaTNSKVAZbnZn3KFkdr1IUIDg$
5 FTC Rule on Unfair or Deceptive Fees to Take Effect on May 12, 2025 | Federal Trade Commission