These comments discuss the dizzying array of junk fees tenants pay to secure and maintain rental housing and how these fees contribute to housing unaffordability and precarity. In addition, these comments provide evidence showing the prevalence and persistence of these fees in the rental housing market. This evidence includes data from a survey that NCLC conducted of legal services providers, nonprofit attorneys, and others working with tenants between March and April 2026. Our comments discuss the 171 responses from 40 states and Washington, DC.
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