Broad Real Estate Coalition Backs Transparency, Cautions FTC of Unintended Consequences as it Seeks to Regulate Rental Housing

ARLINGTON, Va. | April 17, 2026 - The National Apartment Association (NAA), the National Multifamily Housing Council (NMHC) and the Real Estate Technology & Transformation Center (RETTC) led a group of nine other national real estate organizations in submitting joint comments this week to the Federal Trade Commission (FTC or Commission) in response to the agency's Advance Notice of Proposed Rulemaking on "Unfair or Deceptive Rental Housing Fee Practices." The organizations underscored our industry's longstanding resident-centered commitment and support of transparency broadly, while reminding the agency of the unique nature of rental transactions and cautioning that additional complexity could increase costs for renters, divert resources from property operations and weaken the renter experience. Read the coalition's comments.

"Rental price transparency is inherently a fundamental part of our industry, which is built around balancing the business of housing with the humanity of home," said Bob Pinnegar, President and CEO of NAA. "NAA is grateful for the opportunity to work with the Commission to demonstrate our commitment to transparency and underscore the need for balanced, responsible policymaking that acknowledges the importance of flexibility for an industry made up of incredibly diverse portfolios and operating styles."

"Our members build their businesses around strong, long-term relationships with residents, and transparency is at the very core of those relationships," said Sharon Wilson Géno, President of NMHC. "We are eager to work with the Commission to promote clarity in rental housing transactions, but we also urge them to avoid crafting rules that would impose a one-size-fits-all federal regulatory framework that adds to an already complex regulatory environment, and ultimately increases costs and confusion for renters."

"The formation of this coalition demonstrates how seriously the real estate industry takes fee transparency," said Kevin Donnelly, Executive Director and Chief Advocacy Officer of RETTC. "For years, housing providers and their technology partners have been working together to develop innovative, industry-driven solutions that improve the rental experience. Rather than impose requirements that could frustrate that momentum, we urge the FTC to build on the momentum of industry-led efforts as opposed to stifling innovation and ultimately worsening housing affordability."

The coalition is one of the broadest and most diverse groups of rental housing stakeholders ever assembled on this issue. It represents small, medium and large for-profit and nonprofit owners, operators, builders, developers, property managers and service providers across every market segment, including conventional, affordable, military, student and senior housing.

The coalition's comment letter specifically outlined several key considerations for the Commission, including:

• Rental transactions rely on an interactive, multi-step lease process that fundamentally differs from single-point consumer purchases, like concert tickets, hotels and others.
  
• Federal rulemaking must acknowledge the importance of fees, deposits and utilities in pricing structures and acknowledge operational realities. The Commission should clearly distinguish between fee types including mandatory fees, optional fees that are based on resident choices, conditional fees that depend on specific events and pass-through fees, deposits and usage-based charges.
  
• Any federal standards must complement not complicate compliance with existing state and local law. Rental housing is already regulated by a complex web of landlord-tenant and consumer-protection laws at the local, state and federal levels. Layering another potentially conflicting regulation atop existing state and local rules and carefully constructed lease requirements that vary across jurisdictions will raise compliance costs and put upward pressure on rents.
  
• Innovation should be supported, not displaced. Housing providers and technology partners have been investing significant resources for years to develop tools and models for clearer, simpler, and more transparent communication of rental housing costs. The Commission should collaborate with housing stakeholders to build on these efforts.

The coalition noted that nationally, 89 cents of every dollar of rent goes toward necessary operational expenses and cautioned that regulatory requirements that don't account for realities could increase costs for renters.

The twelve organizations signing the coalition comment are the Council for Affordable and Rural Housing, the Institute of Real Estate Management, the Manufactured Housing Institute, the National Affordable Housing Management Association, the National Apartment Association, the National Association of Home Builders, the National Association of Real Estate Investment Trusts, the National Association of Realtors, the National Leased Housing Association, the National Multifamily Housing Council, The Real Estate Roundtable and the Real Estate Technology & Transformation Center.

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The National Apartment Association (NAA), the National Multifamily Housing Council (NMHC) and the Real Estate Technology & Transformation Center (RETTC) partner on behalf of America's rental housing providers and technology suppliers that are driving innovation and helping assist in addressing our long-term housing challenges. Drawing on the knowledge and policy expertise of staff in Washington, D.C., as well as the advocacy power of 139 NAA state and local affiliated associations, NAA, NMHC and RETTC provide a single voice for rental housing developers, owners and operators and suppliers. One-third of all Americans call a rental property home-where, increasingly, technology solutions are being leveraged to modernize property operations, improve housing affordability and enhance the resident experience.