For 10,000+ unit operators, the move-in moment is where a large share of non-rent revenue is created. Application fees, administrative fees, amenity charges, package and utility setup, insurance verification, and the paid moving services a resident selects all land in the same window. That window is now the subject of a federal rulemaking, and the way charges are disclosed at move-in is about to move from a matter of preference to a matter of compliance.
On March 12, 2026, the Federal Trade Commission announced an Advance Notice of Proposed Rulemaking on unfair or deceptive rental housing fee practices, published in the Federal Register on March 13, 2026. The notice asks whether the FTC should require full, upfront disclosure of every mandatory charge before a renter applies for or commits to a lease, and it covers the entire rental lifecycle from application through move-out. Public comments were due April 13, 2026. This article explains what the rulemaking means for the charges you process at move-in, and how to keep that revenue while staying on the right side of the disclosure standard.
What the FTC is actually proposing
The rulemaking targets charges that are not clearly disclosed upfront or that bear no reasonable relationship to the underlying cost of the service. According to the law firm Katten Muchin Rosenman, the notice specifically names application fees, administrative fees, convenience charges, and amenity fees as categories under review, and it contemplates a federal framework for rental fee transparency across the transaction. The full analysis is set out in Katten’s client alert on the proposed rule.
The intent is consumer protection. As the law firm Covington summarized in its Inside Privacy review of the ANPRM, the FTC is evaluating whether hidden or poorly explained charges constitute deceptive practices, as part of a wider federal campaign against so-called junk fees. The direction of travel is clear even before a final rule exists.
The pressure is not federal alone. In April 2026, a bipartisan coalition of state attorneys general, led by New York Attorney General Letitia James, urged the FTC to act on deceptive rental fees. Operators face a converging federal and state expectation that every charge is named, explained, and shown before a resident is asked to commit.
Why this lands hardest at the move-in moment
Disclosure obligations are easy to state and hard to operationalize when charges are scattered across a leasing team, a payments processor, an insurance vendor, and a moving partner. The move-in window is where those charges converge, so it is also where a disclosure gap is most likely to appear. A resident who sees an amenity fee or a utility activation charge for the first time on move-in day is exactly the scenario the rulemaking is written to address.
This is a revenue question before it is a compliance question. Non-rent charges at move-in are a core part of how operators in residential real estate build income beyond rent, and the move-in and move-out revenue workflow is where that income is captured. The risk is not that disclosure rules eliminate these charges. The risk is that a disorganized move-in process forces you to defend a charge you could have simply disclosed cleanly. Protecting the revenue and meeting the standard are the same project.
The compliance exposure, framed as financial risk
Undisclosed or poorly documented fees create measurable financial risk. An enforcement action, a state attorney general inquiry, or a class claim over a single fee type repeated across a 10,000+ unit portfolio is a liability that scales with the size of the book. Renters insurance sits inside this same risk picture. Requiring coverage protects the asset from resident-caused loss, and verifying that coverage at move-in is the point where enforcement is frictionless. A move-in process that captures insurance verification and discloses every charge in one flow turns two separate liabilities into one controlled step.
The paid services a resident chooses during move-in, including movers, packing, and storage, belong on the same disclosed ledger. When these are presented as clearly optional resident selections with transparent terms, they support the resident experience and stay well clear of the mandatory-fee definitions the FTC is scrutinizing. Clean separation of mandatory charges from optional services is one of the strongest protections available under the proposed standard.
What a disclosure-ready move-in looks like
Operators that will adapt fastest share one trait: their charges live inside a single move-in and move-out workflow rather than across disconnected tools. A disclosure-ready process presents every mandatory charge before the resident commits, separates optional services from required fees, timestamps what was shown and when, and produces a record an operator can stand behind if a charge is ever questioned.
Traditional tools focus on task tracking and administrative coordination. Moved embeds revenue-generating services and insurance verification directly into the workflow, which is what makes clean disclosure possible at scale. When the charge, the disclosure, and the record are one system rather than three, compliance stops being a manual audit and becomes a property of the process. For operators standardizing this across a portfolio, the guide to resident onboarding automation covers how the workflow is built.
A practical checklist for portfolio operators
Ahead of any final rule, four moves reduce exposure now. First, inventory every charge a resident can incur from application through move-out and label each as mandatory or optional. Second, confirm each mandatory charge is disclosed before the resident commits, not on move-in day. Third, verify that the amount of each fee has a documented relationship to the cost of the service it covers. Fourth, keep a durable record of what was disclosed to whom and when. A move infrastructure built for multifamily operators produces that record automatically as part of the move-in and move-out flow.
Frequently asked questions
Is the FTC rule final?
No. As of the April 13, 2026 comment deadline it is an Advance Notice of Proposed Rulemaking. The FTC may proceed to a proposed rule or take no further action, but the disclosure expectation is already being reinforced by state attorneys general.
Does this ban move-in fees?
No. The rulemaking targets charges that are hidden, unexplained, or unrelated to the cost of the service. Clearly disclosed charges tied to a real service are the intended safe path.
What about optional services like movers, packing, and storage?
furthermore optional resident selections with transparent terms are treated differently from mandatory fees. The key is presenting them as genuine choices and keeping them separate from required charges.
How does insurance verification fit in?
Requiring and verifying renters insurance at move-in is risk mitigation for the asset, and doing it inside the move-in and move-out workflow keeps enforcement clean and documented.
Get ahead of the standard
The operators who will handle this rulemaking comfortably are ones who disclose cleanly because their move-in and move-out charges already run through one workflow. If you want to see how single move infrastructure captures every charge, verifies insurance, and produces a defensible disclosure record across a 10,000+ unit portfolio, contact Moved to walk through it.