NARPM Submits Formal Comments on FTC Rental Housing Fee Rulemaking

On April 13, 2026, NARPM CEO Troy Garrett submitted a detailed comment letter to the Federal Trade Commission (FTC) in response to its Advance Notice of Proposed Rulemaking (ANPRM) on rental housing fee practices. Here’s what we said — and what it means for you.

Background: Why NARPM Is Engaged

In March 2026, the FTC published an ANPRM titled Rule on Unfair or Deceptive Rental Housing Fee Practices (Docket No. FTC-2026-0266). As we covered at the time, this is the earliest stage of a federal rulemaking that could fundamentally change how rental housing fees are advertised and disclosed. The public comment period closed April 12, 2026.

NARPM has been closely monitoring this issue since before the ANPRM was released — tracking the FTC’s enforcement actions against Invitation Homes and Greystar, watching state legislative activity, and preparing a substantive response.

Read the full NARPM comment letter here (PDF).

Our Core Message to the FTC

NARPM came to this proceeding as a constructive partner — not an opponent of transparency. We acknowledged that the practices documented in the FTC’s enforcement cases against Invitation Homes ($48 million in consumer redress) and Greystar ($24 million in consumer redress and penalties) are real and harmful. We do not defend them.

But we asked the Commission to recognize a critical distinction: NARPM members are not institutional landlords. They are small and mid-sized professional property management firms acting as fiduciaries on behalf of individual property owners. Fees charged to tenants must be authorized by the property owner. NARPM’s Code of Ethics already requires honest, accurate advertising and full fee disclosure — and in most states, real estate licensing laws back that up.

A federal rule built around the worst practices of a few large operators should not be applied uniformly to thousands of small, professional firms that are already operating with honesty and transparency.

What NARPM Proposed

Rather than simply opposing regulation, NARPM put forward a five-part constructive proposal:

1. A Tiered Disclosure Framework
All advertising should include a “Total Monthly Leasing Price” (TMLP) — base rent plus all mandatory recurring fees that apply to every tenant. Before any application fee is collected, providers must disclose all fees in writing, categorized as mandatory, conditional (like pet fees), or optional. The lease itself must include a complete itemized fee schedule.

2. Standardized Disclosure Forms
The FTC should work with NARPM and other industry stakeholders to develop standardized disclosure formats — similar to how mortgage disclosures work — that can be built directly into property management software platforms.

3. Proportionate Requirements for Small Businesses
Compliance costs fall harder on small firms. Any rule should account for that reality — and should place clear obligations on third-party listing platforms and property management software providers, not only on individual property managers.

4. Disclosure Standards, Not Fee Bans
We strongly oppose any rule that would prohibit or cap specific fee categories. These fees cover real, documented costs. Banning them would simply shift those costs into base rent — reducing transparency for renters rather than improving it.

5. A Uniform National Standard
Any federal rule should preempt conflicting state and local disclosure requirements, giving providers and renters one clear, consistent standard in every market.

What Comes Next

The FTC will now review all comments submitted during the ANPRM period and determine whether to move forward with a formal proposed rule (NPRM). If it does, there will be another public comment period on actual regulatory text — and NARPM will be engaged at that stage as well.

This process typically takes several years from start to finish. We will continue to provide timely updates as things develop.

Thank You to Members Who Commented

A special thank you to every NARPM member who submitted their own comment during the public comment period. Individual voices from working property managers carry significant weight in the administrative record — and the ANPRM stage is the most impactful moment to use them. Your participation matters.

For questions about this rulemaking or NARPM’s advocacy efforts, contact the NARPM Advocacy Team.