Key MarginBoutique hotels. Real returns.
Independent boutique hotel investment researchUnited States

Expert Q&A

16. Does the revenue plan depend on fees that cannot be marketed as proposed?

Key Margin research deskSection 06Page 19 of 27

Put to: Greg Duff and the proposed commercial lead.

Why it matters to buyers: The FTC’s Rule on Unfair or Deceptive Fees took effect on May 12, 2025. It addresses price transparency for short-term lodging; it does not prohibit every fee or prescribe its amount. FTC guidance requires mandatory charges to be reflected in the displayed total price, subject to the rule’s specified exclusions and disclosure requirements. (ftc.gov)

Draft framing of a good answer: Ask counsel and the commercial team to examine actual booking journeys across direct, OTA and other channels. Identify mandatory versus genuinely optional items and test how the total price appears as guests make selections.

Then reconcile the commercial forecast. Ask whether a proposed fee adds sustainable revenue, substitutes for room rate, changes conversion or requires additional delivery costs. Do not treat regulatory compliance as proof that guests will accept the charge.

Separate legal display requirements from accounting classification and benchmark reporting.

Sharp follow-up: “Would the projected revenue still hold if every guest saw the complete mandatory price at the first relevant price display?”

Evidence to request: Dated booking-path captures, fee inventory, applicable legal review and conversion or cancellation evidence.

Interview status: No expert response has been recorded.

Sources cited on this page

  1. FTC Rule on Unfair or Deceptive Fees to Take Effect on May 12, 2025 | Federal Trade Commissionftc.gov