On April 27, 2026, District of Columbia Attorney General Brian L. Schwalb filed a complaint against Mid‑America Apartment Communities, Inc., and its subsidiaries (collectively, “MAA”) alleging that the landlord charged illegal fees and misled prospective tenants about the true cost of rent. This action is the latest example of state and federal enforcement scrutiny of rental housing fees.

The Office of the Attorney General for the District of Columbia (“OAG”) alleges that MAA engaged in a pattern of illegal fee practices and deceptive rent advertising in violation of the D.C. Consumer Protection Procedures Act and D.C.’s Rental Housing Act.

According to the complaint, MAA charged fees that are prohibited by District law, including:

  1. a non-refundable $385 “processing fee” due upon lease approval, the purpose of which MMA allegedly failed to explain. This fee is in addition to a separate application fee MMA assesses that District of Columbia law caps at $54;
  2. a $18 “community fee” to cover property taxes, insurance, and maintenance of common areas that MMA allegedly failed to disclose could be used to offset the cost of amenities, while separately charging an additional amenity fee;
  3. a $350 “roommate release fee” when one roommate moved out prior to the end of a lease, an amount alleged to be in excess of the application fee, which the remaining tenant(s) must pay to reapply for the unit as well as any prospective replacement roommate.

Moreover, the OAG alleges that MAA engaged in deceptive advertising by: (1) marketing listings using terms like “base” rent or “starting at”, although tenants were never charged only for these advertised amounts; (2) advertising rental prices that did not include mandatory fees and did not disclose the type or amount of monthly recurring fees; and (3) failing to adequately disclose that MMA would charge fees triggered by certain events, such as the roommate release fee or early lease termination fee.

The latest action by the OAG is part of a broader enforcement trend targeting rental fees. The FTC recently announced an Advanced Notice of Proposed Rulemaking soliciting comment from industry participants and other stakeholders about potential unfair or deceptive acts or practices in the rental housing market. As state attorneys general and the FTC increasingly target fee practices in the rental market, businesses are likely to face scrutiny of how pricing and mandatory fees are advertised and disclosed to consumers, as well as how such fees compare to the actual costs of providing the underlying product or service.

Photo of Jehan Patterson Jehan Patterson

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection…

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection matters.

Jehan is a member of the Advertising and Consumer Protection Investigations group. She represents corporate and individual clients in consumer protection investigations and litigation by the FTC and state Attorneys General and state financial regulators. She advises clients on consumer protection considerations relating to generative and agentic artificial intelligence, state and federal laws governing autorenewal programs, sustainability and other environmental claims, the FTC’s Made in USA rule, the USDA’s National Organic Program, adtech, and other advertising matters. Jehan also represents clients in complex civil litigation involving consumer protection claims.

Before joining Covington, Jehan was a Senior Litigation Counsel in the Office of Enforcement at the Consumer Financial Protection Bureau, where she led investigations into numerous providers of consumer financial products and services for violations of federal consumer financial laws and regulations, including the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts and practices.

Photo of Lucille Bartholomew Lucille Bartholomew

Lucy Bartholomew defends banks, consumer reporting agencies, and other financial services providers and their officers and directors in connection with civil and regulatory enforcement matters and internal investigations. Lucy represents clients throughout all stages of enforcement matters, including civil investigative demand negotiations, document…

Lucy Bartholomew defends banks, consumer reporting agencies, and other financial services providers and their officers and directors in connection with civil and regulatory enforcement matters and internal investigations. Lucy represents clients throughout all stages of enforcement matters, including civil investigative demand negotiations, document production, response preparation, civil investigational hearings, the NORA/15-day letter process, and settlement resolution. She regularly appears before the federal banking agencies, FTC, CFPB, and other federal and state regulators.

Lucy also maintains an active financial services regulatory practice and specializes in UDAAP, credit reporting, fair lending, fees, error resolution, consumer credit, and advertising. 

Photo of Irene Kim Irene Kim

Irene Kim is an associate in the firm’s Washington, DC office, where she is a member of the Privacy and Cybersecurity and Advertising and Consumer Protection Investigations practice groups. She advises clients on a broad range of issues, including U.S. state and federal…

Irene Kim is an associate in the firm’s Washington, DC office, where she is a member of the Privacy and Cybersecurity and Advertising and Consumer Protection Investigations practice groups. She advises clients on a broad range of issues, including U.S. state and federal AI legislation, comprehensive state privacy laws, and regulatory compliance matters.