The FTC is proposing a rule requiring landlords to disclose all mandatory fees upfront. No rule is final and Missouri/Kansas have no state law yet. Key move now: audit your all-in rent charges, take a realistic look at your charges compared to competitors, hold base rent in a competitive range while training leasing staff to walk prospects through your full fee picture and how it compares to the market, and watch for state-level legislation that could move faster than the federal rule.
On March 13, the Federal Trade Commission published an Advance Notice of Proposed Rulemaking (ANPRM) targeting unfair or deceptive rental fee practices. The public comment period closes April 13. This is still early-stage -- not a final rule -- but the direction is clear, and the precedent from states that have already moved tells us how this plays out operationally.
This rulemaking was directly triggered by the FTC's settlement with Greystar, which faced allegations of advertising base rents that obscured hundreds of dollars in mandatory monthly fees. That settlement was the catalyst for Colorado's fee disclosure law, which took effect January 1, 2026, and the FTC has now signaled it wants the same framework applied nationally.
Full rule text: federalregister.gov
What the Rule Is TargetingWhat the Rule Is Targeting
The FTC is focused on the gap between advertised rent and what tenants actually pay. Specifically: application fees, admin fees, amenity fees, technology fees, convenience charges, and other mandatory add-ons that aren't disclosed upfront. The likely requirement is full, all-in disclosure before a tenant applies or commits to a lease.
What Colorado's Experience Tells UsWhat Colorado's Experience Tells Us
Colorado's law is the closest real-world preview we have. Early takeaways from markets where it has taken effect:
- Compliance is operationally heavy -- fee audits, lease rewrites, marketing updates, staff retraining
- Smaller operators are struggling more than institutional players
- Enforcement has real teeth: tenants can demand refunds, and non-response within 14 days triggers triple damages plus 18% interest
- Industry sentiment was broadly "we can live with this" -- but only if the same rules apply equally across competitors
That last point is the crux of the problem in a market like Kansas City where no state rule is in effect yet.
What to Do NowWhat to Do Now
- Audit your fee structure. Map every mandatory charge from application through move-out and know your true all-in monthly number.
- Model your competitive position honestly. Class A properties typically absorb operating costs into high base rents. Class B and C operators have more often used fees as a margin lever, keeping advertised rent competitive while growing effective rent through add-ons. Under full disclosure, that gap becomes visible -- and in some cases tenants may find a nicer unit at a higher advertised rent is actually comparable or cheaper all-in. Know where you stand relative to the market before a rule forces that comparison publicly.
- Don't just disclose -- market it. "No hidden fees. Here's exactly what you'll pay" is a real differentiator with a growing segment of tenants who are already skeptical of add-on fees. Turn a compliance move into a competitive positioning move.
- Be strategic about simplifying. Rolling mandatory fees into base rent will eventually be the right move, but do it carefully. Until a rule is in place and the market adjusts, a higher advertised base rent puts you at a disadvantage with renters using price filters on listing platforms -- they may never see your property. Consider maintaining a competitive base rent for now while equipping your leasing agents to proactively walk prospects through your full fee picture and what they should expect to see at comparable properties. Transparency at the leasing level can be your edge before it becomes a legal requirement.
- Watch Missouri and Kansas legislation. No state-level rule is in effect here yet, but Colorado, Connecticut, Massachusetts, and Oregon have all moved in this direction. A state rule could arrive before the federal one and compress your timeline.
What Changes If This Passes
- Tenants will filter on total cost before touring, increasing price sensitivity at the top of funnel
- Application volume may dip short-term, but close rates should improve as prospects self-select on true cost
- Fewer fee surprises mid-lease means fewer tenant financial hardships -- a real operational benefit
- Advertised rents will likely rise industry-wide as fees get rolled into base rent, but all-in costs stay roughly the same
- Rent comps finally become meaningful -- apples-to-apples comparison becomes possible for the first time
Let's talk through your properties.I'm happy to share what I'm seeing on rents and fee structures across the KC market and help think through how to position your properties competitively ahead of these changes.
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