Total-price display
The total price (including all mandatory fees) must be displayed more prominently than any partial price. We verify the headline price includes all unavoidable charges.
The most rigorous all-in pricing compliance pack a hotel or STR operator can get.
TrueTotal assembles a documentation-complete compliance certification — every statutory element, every required price-display check, the jurisdiction matrix, the evidence log, and the enforcement-response packet — checked against the letter of the FTC Rule and applicable state junk-fee laws before a licensed attorney releases it.
Every subsection of 16 C.F.R. Part 464State-law matrix (CA, MN, VA, CO, CT, IL, MA, NJ)Price-display monitoring across website, booking engine, OTAsLicensed attorney review on every certification5-business-day enforcement-response SLA
Why compliance fails
A single hidden fee can trigger a $50,000 penalty.
The FTC's Rule on Unfair or Deceptive Fees (16 C.F.R. Part 464) took effect May 12, 2025, making it a federal violation to hide mandatory fees behind a lower headline price. States are piling on: California, Minnesota, Virginia already have cross-industry junk-fee statutes; Colorado and Connecticut take effect in 2026; Illinois' Junk Fee Ban Act (effective Jan. 1, 2027) carries civil penalties up to $50,000 per violation. Texas AG Ken Paxton has already extracted a $9.5 million settlement from Booking Holdings and a $1.25 million settlement from Hyatt over hidden hotel fees.
Most hotel and STR operators manage pricing across dozens of rate plans and OTAs manually, from memory, once or twice a year. The patchwork of federal and state rules is growing faster than any manual review can keep up. That is exactly where compliance gaps hide.
TrueTotal exists to close that gap with a single, exhaustive standard applied identically to every property.
$9.5M
Texas AG settlement with Booking Holdings over hidden hotel fees
The benchmark
Measured against the letter of the rule — subsection by subsection.
We do not summarize the law and hope. Every certification is scored against a versioned rule pack tied to the exact text of 16 C.F.R. Part 464 and each applicable state statute. These are the provisions each pack is held to.
Itemized fee disclosure
Any optional or separate fee must be clearly itemized and not misrepresented as a government or third-party charge. We check each fee's description and categorization.
Drip-pricing prohibition
Mandatory fees cannot be added later in the booking flow. We audit the entire checkout funnel for hidden additions.
Jurisdiction mapping
For each property, we apply the state law(s) of the property location and the guest's residence, including CA Civ. Code § 1770(a)(29), MN Stat. § 325F.694, VA Code § 59.1-207.46, CO SB24-184, CT HB 5431, IL Junk Fee Ban Act, MA 940 CMR 3.17, and NJ AG enforcement guidance.
Recordkeeping
All pricing displays and fee disclosures must be retained for at least 24 months. We maintain an evidence log with screenshots and timestamps.
Enforcement-response readiness
Upon receipt of an AG inquiry or demand letter, we produce a signed Enforcement-Response Package within five business days, including the compliance certification, evidence log, and jurisdiction matrix.
How a certification is built
Intake to attorney release, with deterministic gates the AI cannot overrule.
AI extracts and monitors. Deterministic rules — running as code, outside the model — decide what is complete. A licensed attorney reviews and signs every certification and every enforcement response. That order is never reversed.
01
Free Gap Scan
Upload your property URLs and rate plans. We return a free compliance read: which pricing-display elements and state-law requirements you already meet, and which are missing.
02
Continuous monitoring
As your authorized agent, we monitor your website, booking engine, and OTA listings weekly for changes in displayed prices, fees, and disclosures. Screenshots and HTML snapshots are timestamped and stored.
03
Grounded drafting
The compliance certification is drafted from your validated data and the rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Every price display is reconciled against the rule's requirements; the jurisdiction matrix is resolved; the evidence log is complete. Any failure blocks release.
05
Attorney review & signature
A licensed attorney reviews the exception queue and signs the certification. Enforcement-response packages route to attorney review immediately.
06
Delivery
You receive the signed compliance certification, evidence log, jurisdiction matrix, and — if triggered — the Enforcement-Response Package, ready for submission to regulators or use in audit defense.
The bar we hold
Rigor you can measure.
100%
Attorney-signed
No certification ships without a licensed attorney's signature.
5 days
Enforcement-response SLA
From receipt of inquiry to signed response pack.
<1%
Critical-defect target
Tracked against a gold-standard compliance library.
10+
Jurisdictions mapped
FTC + CA, MN, VA, CO, CT, IL, MA, NJ, and growing.
Why TrueTotal
Built to be the most thorough option a property operator has.
Documentation-complete, by design
The deliverable is completeness itself — every statutory element and monitoring check accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run monitoring as your clerical agent. We never give legal advice, set pricing, or interact with regulators on your behalf.
Engagement
Flat fee, per property per quarter. No hourly billing, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any savings or settlement.
- A free Gap Scan before you commit — see exactly what is missing.
- One flat fee per property per quarter for continuous monitoring and quarterly certification; disclosed pass-through monitoring costs.
- Optional Enforcement-Response Package at a flat fee per event.
- Volume discounts for portfolios of 10+ properties.
FAQ
Questions, answered precisely.
Is TrueTotal a law firm?
No. TrueTotal, a service of Your Deputy, Obuke LLC, provides documentation-completeness and monitoring services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is provided by licensed counsel who sign each certification.
Do you set my prices or contact regulators?
Never. TrueTotal does not set pricing, contact regulators, or interact with any government agency on your behalf. You remain solely responsible for your pricing and compliance decisions.
What makes a certification 'complete'?
Completeness is defined by the rule: total-price display verified, itemized fee disclosure checked, drip-pricing prohibition audited, jurisdiction matrix resolved, evidence log complete, and recordkeeping confirmed. Deterministic gates enforce each one before attorney release.
How fast is the enforcement response?
The standard SLA is five business days from receipt of an AG inquiry or demand letter to a signed Enforcement-Response Package. The free Gap Scan is returned much sooner.
How are you priced?
A flat fee per property per quarter for monitoring and quarterly certification, plus a flat fee per enforcement-response event. No hourly billing, no contingency, no percentage of any settlement or savings.
See what's missing before it costs you $50,000.
Start with a free Gap Scan. Send your property URLs and rate plans and we'll return a compliance read against every subsection of 16 C.F.R. Part 464 and applicable state laws.
Documentation-completeness service · not legal advice · you remain responsible for your pricing.