The Fine Print Renters Never See: FTC Warns Property Software Makers

The Federal Trade Commission sent warning letters in December 2025 to companies that make property management software used by landlords nationwide, cautioning that the software's pricing displays do not always show renters the complete monthly cost of a unit, including mandatory fees, and can restrict the ability to convey full cost information to third-party listing sites.DOCUMENTED

The letters summarize the FTC's recent enforcement wins in the rental housing market, including its settlement with Greystar over hidden mandatory fees, and ask each recipient to conduct a comprehensive review of its own pricing-display practices.DOCUMENTED

Why the FTC targeted the software layer

Much of the FTC's prior rental-fee enforcement, including its December 2025 settlement with Greystar, targeted individual landlords and property managers directly over how they advertised rent prices to prospective tenants. The December 2025 warning letters take a different approach, aiming instead at the underlying software infrastructure that many landlords across the industry rely on to generate and publish their pricing listings in the first place.DOCUMENTED

According to the FTC, the property management software at issue does not always display the complete monthly rental price a tenant would actually owe once mandatory fees are included, meaning even landlords with no intent to deceive prospective renters could be relying on software whose default configuration omits or obscures full pricing information. The letters further allege the software can restrict a property manager's ability to aggregate or convey complete cost information when a listing is syndicated to third-party rental listing sites, potentially propagating incomplete pricing information across multiple platforms from a single underlying data source.DOCUMENTED

The legal theory

The letters state that this conduct "harms consumers and may constitute unfair or deceptive acts in violation of the law" under Section 5 of the FTC Act. By addressing the software vendors rather than only individual landlords, the FTC's approach could reach a much larger swath of the rental market at once, since a relatively small number of property management software platforms power listings for a large share of the multi-family rental industry nationwide.DOCUMENTED

Building on the Greystar precedent

The letters explicitly summarize the FTC's recent successful enforcement actions in the rental housing market, referencing the agency's $24 million settlement with Greystar over hidden mandatory fees as an example of the kind of pricing-transparency standard the Commission expects the broader industry, including the software vendors underlying it, to meet going forward.DOCUMENTED

The letters conclude by asking each recipient company to conduct a "comprehensive review of your practices," specifically including both the software's own websites and any client-facing interfaces used to generate rental listings, signaling that the FTC views the full technology stack supporting a rental listing, not just the landlord's own advertising decisions, as within scope of its pricing-transparency expectations.DOCUMENTED

A warning, not yet an enforcement action

Unlike a formal complaint or consent order, a warning letter does not itself constitute a finding of liability, nor does it guarantee that any of the recipient companies will face a future enforcement action. Warning letters function as the FTC's mechanism for placing an industry on notice about a specific practice the agency considers legally risky, often preceding a subsequent wave of formal complaints once companies have had an opportunity to review and correct the flagged conduct.REVIEWED

Part of a broader rental-market enforcement priority

The letters arrived within the same general window as Chairman Andrew Ferguson's stated intention to develop a formal rule addressing unfair or deceptive fees specifically in rental housing, following the Greystar settlement. Taken together, the software warning letters and the prospect of a dedicated rental-fee rule suggest the FTC intends to address rental-pricing transparency from multiple angles simultaneously: individual enforcement actions against landlords who mislead tenants directly, warnings aimed at the software vendors whose tools shape how pricing is displayed industry-wide, and a potential rulemaking that would formalize disclosure standards across the entire rental housing sector rather than relying solely on case-by-case enforcement.

By targeting the software layer rather than only individual landlords, the FTC's approach could, if it eventually leads to a formal rule or enforcement action, address pricing-transparency gaps at a structural level across the rental industry rather than one property manager at a time. Because a relatively concentrated set of property management platforms power listings for a large share of the multi-family rental market nationwide, correcting default configurations at the software level carries the potential to reach far more individual rental listings than any comparable number of company-by-company enforcement actions against landlords alone.REVIEWED

Because the letters stop short of naming the specific software companies involved or detailing individual product configurations, the practical effect for renters in the near term remains limited to whatever voluntary compliance reviews the recipient companies choose to undertake. Whether the FTC follows these warning letters with a formal complaint against any specific software vendor, as it did following its own warning letters preceding the Consumer Review Rule's first enforcement actions, will determine how quickly the underlying pricing-display gaps the letters describe are actually closed.REVIEWED

Because rental listing syndication typically flows from a single property management platform out to multiple third-party listing sites simultaneously, any pricing gap embedded at the software level can appear consistently across every platform where a given unit is advertised, potentially making an incomplete price look independently confirmed across multiple sources even though all of them trace back to the same underlying, incomplete data feed.REVIEWED

Housing policy researchers have noted that addressing pricing transparency at the software layer, rather than case-by-case at the level of individual landlords, mirrors a broader regulatory strategy the FTC has increasingly applied across other markets where a small number of shared technology vendors power a disproportionate share of an entire industry's customer-facing pricing decisions, treating the underlying software as a more efficient point of intervention than pursuing every downstream user of that software individually.REVIEWED

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