FTC Issues Warning Letters To Property Management Software Providers On Price Transparency

Atlanta, Ga. (December 23, 2025) - On December 8, 2025 the Federal Trade Commission ("FTC") sent what it is describing as a "Warning Letter" to companies that provide property management software to landlords ("Software Providers"). While the letter does not speak specifically to landlords, landlords can still use the information contained in the letter to adopt best practices to avoid potential enforcement action.

The Warning Letter references two high profile civil enforcement actions the FTC has undertaken in the last two years: FTC v. Invitation Homes, and FTC v. Greystar Real Estate Partners, LLC, et al., two cases in which the FTC targeted landlords for what it deemed unfair or deceptive advertising practices. Citing those cases, the FTC warns software providers that they must provide platforms on which landlords can accurately advertise the total monthly cost of a rental property rather than simply advertising the monthly rental payment. The FTC then warns that failure to create platforms that share the total monthly payments may result in enforcement action.

The following is our advice on how landlords should adapt in response to the Warning Letter:

• You MUST disclose all mandatory fixed fees and a total of monthly payments before accepting any payments or entering into binding agreements with the tenant. While the form of disclosure is not set by the FTC, a landlord is required to identify the total cost in its advertisement.
• It is ADVISABLE, but not specifically required, to disclose the total monthly cost on the heading or thumbnail for the advertisement.
• It is ADVISABLE, but not specifically required, to disclose the total monthly cost in a summary on the first page of the lease.

The FTC's cases targeted Greystar and Invitation Homes for failing to disclose fees. Both entities waited until after an application was submitted and an application fee paid to disclose the totality of the fees. Both entities settled, agreeing to the entry of a monetary judgment against them and to advertise in a way that was approved by the FTC. Their advertisements now appear as follows:

As you can see, both entities—which have secured FTC approval for their advertisements—list the total monthly cost (rent plus monthly mandatory fixed fees) on the thumbnail for the property.

Strictly applying the holdings in the Greystar and Invitation Homes cases, the only thing that is clearly required at the moment is that the fees be disclosed before the resident pays an application fee, signs a lease, or otherwise expends resources on the rental. However, the agency has clearly shown what it considers to be sufficient notice of fees based on the negotiated advertisements both defendants are now using. The best practice to avoid potential enforcement actions by the FTC, in case it changes the policy or interprets its own language differently than we do, would be to mirror those advertisements.

As to whether the summary of total costs is required to be included in the lease, the FTC has not provided explicit direction on this issue. The Greystar case touched on the fact that the mandatory fees were buried in the lease, but the gravamen of that case was that the fees were not disclosed at all until after nonrefundable deposits were paid. The December 8, 2025 letter does not address leases specifically, but the letter also states that it "is not intended to be a comprehensive statement of concerns[.]"

Given this uncertainty, the best practice to avoid enforcement would be to include a summary on the first page of the lease that identifies every fixed mandatory monthly fee and lists any other amounts (e.g., utilities) which may change from month to month. Again, the FTC has not specifically targeted leases yet, but the FTC's message is clearly that they want renters to see the total monthly outlay "up front." Given the current guidance from the FTC, you are not required to include a summary in your lease, but doing so may avoid enforcement actions in the future.

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