On December 2, 2025, the Federal Trade Commission (FTC) and the State of Colorado announced a $24 million settlement with Greystar, requiring the company to “clearly and conspicuously display total monthly leasing prices and mandatory fees.”

Days later, the FTC published a follow-up business guidance post making the new expectation explicit for the entire industry. The agency wrote: “Advertising a rental price that excludes mandatory charges is a violation of the law.”

And on December 9, the FTC sent warning letters to 13 property management software providers, signaling that tech stacks that inhibit transparent pricing may themselves violate federal law.

The Three Headlines Every Operator Should Internalize

1. Mandatory fees must now be reflected in the upfront advertised price

The FTC’s position is unambiguous. If a fee is mandatory and recurring, it must be included in the advertised rental price—not surfaced late in the leasing process or buried in disclosures.

2. Operators are responsible for their vendors’ pricing displays

The FTC emphasized that landlords and managers must ensure that “third-party vendors accurately advertise the rental price on all their platforms.” This shifts responsibility from passive compliance to active oversight.

3. Your software stack is now part of your compliance framework

In the warning letters to software providers, the FTC noted that tools preventing accurate pricing display could face consequences including civil penalties of up to $53,088 per violation .

“But We’ve Always Advertised Base Rent.” That’s Exactly the Problem.

In its public statement, Greystar noted the settlement contains no admission of wrongdoing and that the industry has long advertised “base rent.”

The FTC clearly disagrees with that approach. The new standard shifts the industry toward a consumer expectation that the first advertised number should represent the true monthly cost.

Where Do Resident Benefit Packages Fit Into This?

Any model involving mandatory, recurring fees not reflected in the upfront advertised price now sits squarely in the zone of regulatory risk. The FTC does not care what the package is called. It cares whether residents can avoid it and whether the advertised price reflects it honestly.

A 7-Minute All-In Pricing Audit Every Operator Should Run Today

1. List every recurring charge

Separate mandatory vs. optional. The FTC’s position centers on mandatory fees.

2. Check whether residents can opt out

If not, it’s mandatory for pricing purposes.

3. Review your “first impression” pricing

Inspect your website, listings, and ads. Ensure the total monthly price is visible before application fees are collected.

4. Ensure third-party listings are compliant

The FTC expects operators to coordinate with internet listing sites and the vendors who syndicate listings to ensure advertised prices are accurate.

5. Confirm your software can surface an all-in price

This matters now that software tools themselves have received FTC warnings.

6. Fix language that creates “junk fee” optics

Many fees aren’t inherently problematic. Surprises are.

7. Document everything

If you ever need to demonstrate compliance intent, documentation helps.

The Opportunity Hidden Inside the FTC’s Crackdown

Transparency doesn’t make you less competitive. It makes you more trusted. The FTC specifically noted the importance of allowing consumers to make apples-to-apples comparisons and avoid wasted time and application fees.

In 2026, transparency becomes a brand advantage.

What If You Rely Heavily on Mandatory Monthly Fees?

You do not need to abandon ancillary revenue.

• Bake mandatory fees into the advertised rental price.
• Convert borderline items into truly optional offerings.
• Shift revenue toward transparent, value-based services like utilities or internet setup.

This is where platforms like Utility Profit can help operators maintain revenue while avoiding “junk fee” optics entirely.

Copy/Paste: An Internal Email You Can Send Your Team Right Now

Subject: Action Required: All-In Pricing (FTC) — Audit Our Listings + Mandatory Fees

Team,

This week the FTC signaled that advertising a rental price without mandatory charges is unlawful and that operators must ensure transparency across websites and third-party platforms.

By Friday EOD, please:
1) Identify all mandatory monthly fees at each property.
2) Confirm our advertised rent matches the true total monthly price.
3) Verify our software and vendors can display and syndicate all-in pricing.
4) Flag any mandatory packages/fees not surfaced up front.

Final Thought

If a renter cannot avoid a fee, they should not discover it later. The FTC just turned that common-sense principle into a national enforcement standard.