The FTC’s September 2024 action against Invitation Homes put fee advertising, move-in preparation and security-deposit practices under scrutiny. For property management leaders, the useful operational question is whether a prospective resident sees a consistent, accurate explanation of costs—and whether the company can substantiate charges later.
This article was first published on 4 October 2024. The timeline below distinguishes the original allegations, the entered settlement order and the subsequent refund announcement.
The case and its later update
The FTC announced its action on 24 September 2024, alleging that Invitation Homes misrepresented rental costs, imposed undisclosed fees, failed to inspect homes before move-in and unfairly withheld deposits, among other practices. These were the FTC’s allegations; they should not be described as findings following a trial. The original FTC announcement sets out the claims.
The court entered a stipulated order on 27 September 2024. It required $48 million in monetary relief and imposed obligations on Invitation Homes concerning pricing disclosures, deposits and other conduct. The FTC case record links the entered order and complaint.
On 11 March 2026, the FTC announced more than $47.2 million in checks to 444,131 eligible consumers. That distribution is a later implementation event, not a second $48 million settlement. The refund announcement explains the covered charges and eligibility.
The order binds Invitation Homes and those acting with it. It does not create one identical operating rule for every property management company. Your obligations still depend on applicable law, agreements, property location and the conduct involved.
Two provisions in the entered order make those obligations concrete:
- Pricing: Invitation Homes must show the total monthly leasing price, including recurring mandatory fees, more prominently than other pricing information. The order makes an exception for responses to resident questions about particular fees.
- Deposits: Deductions are limited to actual resident-caused damage beyond normal wear, exclude pre-existing conditions and must be used to repair the damage. Residents must receive an itemized explanation of the charges and their responsibility.
These defendant-specific requirements explain why the review below follows both advertised costs and the evidence behind deductions.
Follow the price through the entire leasing journey
Pick a current vacancy and compare the listing, enquiry response, showing information, application process and lease package. Can a prospect understand the required costs before making the relevant commitment? Are mandatory and optional services described accurately? Does the website reflect the same terms as the leasing team’s script?
Use a simple fee record:
| Field | What to establish |
|---|---|
| Charge and amount | Exact name, calculation and frequency |
| Payer | Resident, applicant or owner |
| Status | Required, optional, conditional or refundable |
| Authority | Applicable agreement and legal review |
| Disclosure point | Where the person sees it before the relevant decision |
| Operational owner | Person who updates every affected channel |
The record is an internal control, not permission to impose a fee. Have the appropriate adviser review the charges and disclosure requirements for your jurisdictions. When a fee changes, update every affected channel together and retain the approved version.
A common practical gap is a leasing employee answering from memory while the website shows an older amount. Centralizing the approved facts and checking sample enquiries can reveal that mismatch. Our guide to rental enquiries and follow-up explains the related team handoffs.
Make deposit decisions traceable
A defensible operating process connects the condition at move-in, the condition at move-out, the reason for a proposed deduction and the evidence supporting the amount. Record who reviewed the decision and which applicable requirements governed it.
Do not use a standard charge list as a substitute for evaluating the facts. A damage allegation, normal wear, an existing defect and an improvement are not interchangeable descriptions. Your company’s legal advisers should define the applicable rules, including deadlines and required communications; software reminders help execute those rules but do not determine them.
In an illustrative file review, the team finds a proposed appliance deduction without a move-in condition record. The next step is to investigate the missing evidence and review the basis for the charge. It is not to treat a blank field as proof that the appliance was previously undamaged.
Inspect the handoffs that create misleading information
The case’s move-in allegations are also a reason to compare what leasing promises with what maintenance has actually verified. “Ready for move-in” should correspond to the company’s documented readiness checks and the facts of that property.
Assign responsibility for releasing that status, changing it when work is incomplete and notifying the prospective resident about a material change. A signed work order, an invoice and a verified completed repair can represent different stages; the team needs a shared definition.
Review a sample of recent files across leasing, maintenance and accounting. Look for contradictory prices, unsupported charges, missing approvals and commitments that were never closed. Record corrections and review the affected workflow, rather than treating every inconsistency as an isolated employee mistake.
Our tenant-management guide connects those responsibilities across the resident relationship. BetterTeam Consulting can help clarify the roles and management routines needed to carry out approved policies consistently.
