FTC Signals Heightened Scrutiny of Rental and Prop-Tech Pricing Platforms

By: Steve Albertson , Eric Ball , Kimberly Culp

What You Need To Know

  • The Federal Trade Commission (FTC) sent warning letters to 13 property management software providers, indicating increased scrutiny of how mandatory fees are disclosed in rental listings and building on recent enforcement actions addressing price transparency.
  • The agency cautions that platform designs or settings that obscure the full cost of rent may violate Section 5 of the FTC Act.
  • The FTC’s emphasis on complete price disclosure is consistent with broader initiatives against hidden fees and may have implications for tech platforms beyond the rental market.

The FTC recently escalated its focus on pricing transparency in the residential rental market, signaling broader regulatory risk for technology platforms that influence how rental pricing is presented to consumers. Pricing transparency has been an ongoing enforcement priority for the FTC, and this development builds on a series of recent enforcement actions aimed at ensuring that advertised prices reflect the total cost of goods and services.

Key Developments Amid the FTC’s Focus on Price Transparency

On December 9, 2025, the FTC sent warning letters to 13 property management software providers nationwide, notifying them that they may be violating federal law by limiting the ability of property managers and owners to accurately advertise total monthly rental prices, including all mandatory fees. The action follows a recent multimillion-dollar settlement with a major rental operator in which the FTC alleged deceptive pricing practices.

In its communications, the FTC emphasized that software design or practices that hinder the flow of complete pricing information in rental listings can deprive consumers of the ability to make informed decisions and potentially harm market efficiency. The letters remind recipients of the FTC’s authority under Section 5 of the FTC Act to investigate unfair or deceptive acts or practices and the potential for enforcement actions, including injunctions and civil penalties, if unlawful conduct is found.

This development comes on the heels of the Department of Justice’s (DOJ’s) November 24, 2025, settlement of its antitrust case against RealPage, a provider of revenue management software to operators of multifamily rental properties. Central to the allegations made by DOJ and a number of states’ attorneys general was the charge that RealPage’s platform generated pricing recommendations using prices charged by competing landlords, with the purpose and effect of raising rents across the industry. Together with the FTC’s recent push on pricing transparency, DOJ’s actions demonstrate a clear resolve on the part of federal regulators to closely scrutinize pricing practices that may tend to lead to higher rents.

Why This Matters

Although the current letters do not allege violations against the software providers named, they reflect a broader shift in regulatory scrutiny: The FTC is looking beyond property owners and managers to the digital systems that shape how pricing information is communicated. Technology platforms that influence price presentation, reporting, aggregation, or disclosure, whether directly or through default settings, data feeds, APIs, or listing integrations, may now find themselves within the FTC’s analytical lens.

This trend parallels other recent regulatory initiatives emphasizing total price disclosure and against “hidden” or “junk” fees in consumer markets, suggesting that the FTC views pricing transparency as a cross-sector priority.

Practical Considerations for Platforms and Software Providers

Companies whose products facilitate rental property management, listings, or pricing workflows should consider the following:

  • Review pricing display practices. Assess whether your platform’s default settings, templates, or API integrations enable or discourage the display of all mandatory fees alongside base rental prices.
  • Evaluate data flows and disclosures. Examine how fee information is captured, stored, and transmitted to third-party listing sites or marketing channels. Ensure that mandatory charges are not inadvertently excluded or obscured.
  • Update documentation and training. Strengthen internal guidance for clients and users on best practices for total price disclosure consistent with FTC expectations.
  • Consider proactive compliance counseling. Engage legal counsel to evaluate whether product features, integrations, or pricing presentation mechanisms raise risk under Section 5 of the FTC Act and related consumer protection laws.

Looking Ahead

The FTC’s actions indicate that pricing transparency is a focal point for enforcement, particularly where technology plays a central role in shaping consumer perceptions and competitive dynamics. Companies with exposure to rental pricing, property-tech platforms, or software that influences how prices and fees are displayed should monitor developments closely and consider proactive compliance strategies. Although the FTC sent these warning letters to technology platforms in the rental market, other technology platforms that control how their users display pricing and fees should evaluate whether the platform design allows users to display all-in pricing to consumers.