Does the federal rule ban resort fees?
No. It regulates price transparency and misrepresentation, not the existence or amount of every fee. Since May 12, 2025, the FTC rule has required covered sellers to present the total price, including mandatory charges, upfront. Its coverage includes third-party platforms and business-to-business transactions. FTC implementation announcement; FTC compliance FAQ. (ftc.gov)
Government charges can be excluded from the initially displayed total under the federal rule, but required disclosures and the final payment amount must be provided before payment. A charge is not genuinely optional merely because staff remove it when a guest complains. FTC compliance FAQ.
Recommended acquisition test: Make controlled test reservations through the hotel website, mobile journey, telephone desk and major intermediaries. Preserve screenshots showing the first price, mandatory charges, optional selections and final amount.
For underwriting, request a bridge between historical room revenue, mandatory-fee revenue and the proposed presentation. Do not assume that changing the advertised price automatically changes accounting classification, commission obligations or management-fee definitions; request the relevant agreements and accounting policy.
What additional NYC deadline is approaching?
January 22, 2027 is the specific deadline for the new hold/deposit-policy disclosure—not February 2026. The adopted rule requires disclosure of the general policy, standard amount, reasons for retaining funds, and approximate release or refund timing before consent to pay. Its principal pricing provisions took effect February 21, 2026. Adopted NYC rule, §5-15. (codelibrary.amlegal.com)
DCWP’s guidance describes the pricing requirements as applying to hotel stays in NYC or offers to NYC residents, including through third-party travel websites. An out-of-city owner should therefore obtain a scope assessment rather than assume physical location resolves applicability. DCWP hotel FAQ.
Do now: Assign one approved deposit policy across the booking engine, confirmation messages, front-desk scripts and intermediary content feeds. Ask counsel to distinguish disclosures already required from the additional January 2027 provision.