50 State Brokerage

Your pricing violation probably lives in your software

Multi-state brokerage compliance — September 24, 2026. The FTC warned thirteen property management software providers that their platforms can create the pricing violation; Maryland submetering takes effect October 1 and Utah's property manager license now has a date.

A weekly read on what changes for companies operating under real estate licenses in more than one state. Every item links to the primary source.

Your pricing violation probably lives in your software

The FTC's rental pricing enforcement has moved one layer up the stack. After settling with Greystar for $24 million over advertised rent that excluded mandatory fees, the Commission sent warning letters to thirteen property management software providers — telling them that if their platforms prevent an owner or manager from displaying the true total monthly price, the software provider itself may be violating Section 5. Civil penalties run to $53,088 per violation.

The letters ask recipients to audit their hosting platforms, their code, and the data flows feeding listing sites. That is a technical review, not a policy one.

What this means for you: you can have a correct fee policy and still advertise an illegal price, because your PMS or your syndication feed drops mandatory fees on the way to the listing site. Pull up three of your own live listings on a third-party portal and compare the advertised number against what a tenant actually pays in month one. If they don't match, the gap is your exposure regardless of who built the software. Then check whether your vendor agreement lets you demand a fix. Source: FTC — warning letters to property management software providers

Coming, and worth handling early

Maryland — October 1, 2026. One week out. SB 130 / HB 220 takes effect. It authorizes water submetering in apartment houses and mobile home parks, bars passing through more than the water provider actually charges, and adds recordkeeping, leak-monitor and tenant-inspection duties.

What this means for you: if you submeter or use RUBS in Maryland, your October billing cycle is the first one under the new rules. Two things to confirm this week: that your billing vendor can cap the pass-through at actual cost, and that your lease language matches what you are about to charge.

California — AB 747, the SPARE Act, 2027. Proof-of-service documentation requirements in unlawful detainer cases increase substantially.

What this means for you: this lands on your eviction vendor and your record retention, not your leases. If service records live in someone else's system, find out now what they will be able to produce.

Already in effect

New York — since September 16, 2026. The Attorney General's Real Estate Finance Bureau adopted amendments to 13 NYCRR Parts 18 and 23, governing offering plans for converting occupied residential rental buildings to co-op or condo ownership in New York City. The amendments apply to plans submitted on or after June 15, 2019, including plans already accepted for submission but not yet accepted for filing.

What this means for you: narrow, but sharp if it touches you. If you have a conversion plan sitting in the queue, the rules it will be judged under changed while it was waiting. Source: NY AG — recent rulemaking

Not law yet — watch these

Utah — now with a date. The Real Estate Rules Committee is still drafting the proposed property manager rule and has not yet presented it to the Real Estate Commission. The new property manager license is currently set to become available January 1, 2027.

What this means for you: you have a quarter. The rule governing trust-account association and scope is still being written, which means the comment window is open and the requirements you will be held to are not yet fixed.

FinCEN. The Residential Real Estate Rule remains vacated by the Eastern District of Texas, and FinCEN and DOJ have appealed. While the order stands, reporting persons are not required to file and face no liability for not filing. Source: FinCEN — Residential Real Estate Rule

What a regulator actually asks for

A designated broker can resign. Most operators don't find out what that costs until it happens.

The license that authorizes your entity to operate in a state is attached to a person. When that person leaves, the entity's authority typically lapses on a clock — often thirty days, sometimes less — and in most states you cannot close a transaction, collect a commission, or in some cases even hold funds in the interim. Your listings don't pause politely while you recruit.

What this means for you: ask two questions about every state you operate in. How many days do you have after a broker departs, and what specifically are you prohibited from doing during that window? Then ask a third about your own arrangement: is your broker a person you know, or a person your vendor knows? The answer determines whether a resignation is a phone call or a shutdown.

Elsewhere

  • Federal — Greystar, the largest multifamily manager in the country, paid $23 million to the FTC and $1 million to Colorado over advertised prices that excluded mandatory fees.
  • Federal — Invitation Homes paid $48 million in 2024 over junk fees, withheld security deposits, and eviction practices. The single-family side is not being treated differently from multifamily.
  • Federal — RealPage and DOJ settled the antitrust case over multifamily revenue management software. If you license pricing software, read the terms of that settlement before your next renewal.
  • California — AB 325 and SB 763 raise state-level scrutiny and penalties around rent pricing practices, layered on top of the federal posture above.

50 State Brokerage provides designated, managing and qualifying broker coverage in 30+ states for PropTech companies, SFR and build-to-rent operators, and property management firms. Book a call.

This describes regulatory developments and is not legal advice.

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