KAREN ELIZABETH CHRISTIAN+1 202.887.4265/fax: +1 202.887.4288
kchristian@akingump.com

CONFIDENTIAL TREATMENT REQUESTED
December 19, 2022

VIA ELECTRONIC MAIL
The Honorable Elizabeth Warren
The Honorable Tina Smith
The Honorable Bernie Sanders
The Honorable Edward J. Markey
United States Senate
Washington, D.C. 20510
Re: Letter to RealPage, Inc., Dated November 22, 2022
Dear Sens. Warren, Smith, Sanders, and Markey:
On behalf of RealPage, Inc. (“RealPage”), I am writing in response to your letter dated
November 22, 2022 (the “Letter”), requesting information concerning RealPage’s revenue
management software, YieldStar. RealPage appreciates the opportunity to explain how YieldStar
works, the efficiencies it provides to apartment providers and residents, and its role within rental
housing in the United States. RealPage’s revenue management software products were the focus
of a recent article in ProPublica, which was cited throughout your Letter. As explained in moredetail below, that article and other recent news coverage of RealPage’s revenue management
software (largely based on the article) do not accurately describe how these products work, inparticular with regard to the role that data about other properties plays in generating rent pricerecommendations for RealPage’s customers and the effect that the use of these products has had
on rents and apartment occupancy rates. We appreciate the cooperative discussions we have hadwith your staff to date and the extension of time to submit this response.
I.

REALPAGE BACKGROUNDRealPage was founded in 1998 and is headquartered in Richardson, Texas. For nearly 25
years, RealPage has offered a broad portfolio of property management software products andservices to help its customers—owners and managers of rental properties for conventional,
affordable, military, student, single-family, senior and vacation housing, and homeowners
associations—better operate their communities and improve performance, including by enhancing
the rental experience for consumers. RealPage’s products and services provide its customers withsolutions for many aspects of property management and ownership, including marketing, leasing,The Honorable Elizabeth Warren
The Honorable Tina Smith
The Honorable Bernie Sanders
The Honorable Edward J. Markey
December 19, 2022
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resident experience, site management, expense management, and vendor management. RealPage
also uses data insights to help customers achieve their financial and sustainability goals.
Customers use RealPage’s products and services to reduce inefficiencies, proactively mitigate risk,
improve the rental experience for residents and prospective residents, and increase resident
satisfaction and retention. RealPage products also offer residents and prospective residents
enhanced options for finding and leasing apartments that better fit their needs with respect to leaseterms, move-in dates, and amenities. These products make the rental experience more convenient,while simultaneously providing residents and prospective residents with increased pricing
transparency.
RealPage’s focus on developing products and services that benefit both apartment
providers and residents has been critical to the company’s success. By way of example,
RealPage’s Resident Services offerings automate many time-consuming administrative andoperational functions such as lease renewals, package tracking, and utility billing, affording local
property staff substantially more time to attend to the specific needs of residents. Resident Services
products also include an online resident portal that allows residents to manage rent payments,
submit service requests, reserve amenities, and renew leases from their mobile devices. In
addition, RealPage’s Utility Management offering helps apartment providers unlock savings
through more efficient electricity, gas, and water consumption, while RealPage’s Submetering
service—allocating utility costs to residents based on actual consumption—provides substantial
savings to residents who prioritize energy conservation. The Renters Insurance service helps
customers limit losses by maximizing coverage for residents, while RealPage’s eRenterPlan
provides residents accessible, affordable, and comprehensive insurance plans. RealPage alsooffers RealPage Rent Reporting, an optional subscription service that helps residents build their
credit profiles by automatically reporting their monthly rent payments to the major credit reporting
bureaus.
During the COVID-19 pandemic when in-person interaction was unadvisable or even
impossible due to the health emergency and related lockdowns, RealPage’s innovative products
and services were critical to enabling apartment providers to continue serving their residents
remotely and efficiently. By utilizing RealPage technology, apartment providers and residents
alike were able to benefit from online software making possible the ability to (i) conduct remoteapartment searches, online tours, and leasing transactions; (ii) make rent and utility payments
without dropping off checks at the leasing office; (iii) monitor utility usage while living andworking from home; and (iv) remotely obtain apartment maintenance and service through an
online resident portal, and other similar resident-friendly conveniences that are now becoming
standard expectations of many apartment residents. During the pandemic, RealPage also provided
data to the U.S. Department of Housing and Urban Development about rent and rent collections toThe Honorable Elizabeth Warren
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assist the government in its administration of vital programs, including the Housing Choice
Voucher Program.
Across all its products and services, RealPage’s purpose is to inspire amazing experiencesand deliver exceptional value. RealPage continually works to identify and develop innovative
solutions to simplify and streamline the rental experience with products and services that promote
efficiency, accountability, and consistent quality for apartment providers and residents alike.
Recognizing that each RealPage customer has its own unique circumstances and goals when
making decisions about how to organize, manage, and operate its properties, RealPage iscommitted to providing its customers with information to help them make better decisions.
YieldStar, which is just one of the many products and services that RealPage offers, fits squarely
within this mission.
II.

REVENUE MANAGEMENTRealPage began offering YieldStar, a revenue management software product, in 2005.1
Before explaining how the YieldStar product works, it is important to note that revenue
management is not unique to RealPage, or to rental property markets. Indeed, revenue
management tools have been deployed for decades and are now ubiquitous in industries where
effective management of inventory is critical, including the travel, hospitality, and groceryindustries. Governmental authorities also rely on revenue management tools for use cases such asdetermining pricing for highway express lanes relative to normal toll lanes. Compare, for example,
a department store to a hotel. If a department store fails to sell an article of clothing at a particular
price point, it always has the ability to sell the same article of clothing at a later date for a lower
price. By contrast, if a hotel fails to find the right price point for a vacant room prior to the night,
it permanently loses the opportunity to earn a profit on that vacant room. The same principle holds
true for airline seats and perishable food. While rental units involve consumers with longer
transaction durations than a single flight or hotel stay, the same general principle applies. Revenue
management tools help businesses in these industries and others use performance and analytics
data to identify the optimal level at which to price inventory for sale at a particular point in time.
Revenue management technology was introduced in the multifamily housing industry in
the early 2000s. Apartment providers use revenue management software as one input to determine
the prices at which they offer apartments for rent based on supply (available units) and demand
1
YieldStar is one of three revenue management products offered by RealPage. As the questions set forth inyour Letter address YieldStar, the information included in this response focuses on this software unless otherwise
indicated.

The Honorable Elizabeth Warren
The Honorable Tina Smith
The Honorable Bernie Sanders
The Honorable Edward J. Markey
December 19, 2022
Page 4(prospective and current residents) at a particular property. Importantly, the purpose of revenue
management tools is not to increase rent at each property at every opportunity, but to manage
revenues such that they are aligned with the apartment provider’s individual needs and asset
strategy for that property.
Contrary to the assertions made in the recent ProPublica coverage about the use of revenue
management software in rental housing and its effect on occupancy, the increased adoption ofrevenue management technology by apartment providers over the past decade has correspondedwith a decrease in rental vacancy rates. In fact, since RealPage launched its first revenue
management product, national vacancy rates have plummeted from over 10% in the early 2000s
to just 6% as of the third quarter of 2022.2 In both 2021 and 2022, the United States reachednational vacancy rates of 5.6%, the lowest rates since 1984.3 While it is difficult to differentiate
the impact of revenue management tools like YieldStar from other market forces that affectoccupancy rates, the fact that apartment providers now have commercial revenue management
products available to them has not resulted in a national increase in vacancy rates. In fact, as
discussed below, properties using YieldStar routinely achieve vacancy rates below the national
average.
III.

HOW YIELDSTAR WORKS

As mentioned above, RealPage began offering YieldStar, its first revenue management
software product, in 2005. During the intervening years, RealPage has competed with otherrevenue management solutions available to apartment providers across the United States to aid its
customers in the management of their properties.

2

Federal Reserve Bank of St. Louis, Rental Vacancy
https://fred.stlouisfed.org/series/RRVRUSQ156N (last visited Dec. 19, 2022).
3
Id.
4

Rate

in

the

UnitedStates,The Honorable Elizabeth Warren
The Honorable Tina Smith
The Honorable Bernie Sanders
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Consistent with other revenue management products on the market, YieldStar uses a
proprietary algorithm to make recommendations to apartment providers about setting a price forrental units at their property that aligns with their individual strategic objectives. However, theYieldStar software is fundamentally built on the disruptive idea that a property’s internal supply
and demand dynamics are much more important than external factors, such as rents offered byother properties, when recommending appropriate rental prices for the subject property. As aresult, YieldStar prioritizes a property’s internal rent data (what renters agree to pay for units atthat property) and internal availability data (unit and unit types that are or will be coming available
for rent at that property) when recommending whether a rental price should be increased,
decreased, or remain at the current level. The data types considered and the general manner inwhich the YieldStar algorithm operates are described below.
YieldStar generates recommendations for the prices for each unit type (that is, by floorplan, meaning 1-bedroom units, 2-bedroom units, etc.) at a customer’s particular property. The
customer then decides the price to offer—for example, by accepting the recommended price orapproving an alternative price—and the software presents the approved prices in a matrix based

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The Honorable Tina Smith
The Honorable Bernie Sanders
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December 19, 2022
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on various potential lease start dates and term lengths. At a high level, the YieldStar algorithm
determines a recommendation in two basic steps.
In the first step, the algorithm considers, for a particular floor plan, the expected supply ofavailable units of that floor plan at the subject property in the future. The
data used to assess this is the property’s own internal lease data
Then, the algorithm assesses recent demand
relativeto expected demand for that floor plan at that property. The forecasted demand is based on internal
historical data
for the subject property.
This builds the historical seasonality of the subject property and floor plan to project any
supply/demand imbalances for that specific property that should be expected in the future. Basedon this internal information about expected imbalances in supply and demand, YieldStar
recommends whether the rent price for the particular floor plan should remain the same, increase,or decrease.
If in that first step YieldStar’s algorithm determines that the current price is appropriate,
then it will recommend that the current price for the floor plan be maintained. If, however, in thatfirst step it is determined that a supply/demand imbalance for that specific property is expected
and thus that a price adjustment should be considered—either upward or downward—thealgorithm moves to the next step. In the second step, the software uses aggregated, anonymized
data from multiple sources about publicly available asking rents or actual, historically achieved
rents at similarly situated properties to help determine the price elasticity of demand, that is, howsensitive renter demand for the specific floor plan at the subject property will be to upward or
downward adjustments in price. Based on this, the algorithm recommends the appropriatemagnitude of any rent adjustment. This approach is critical to ensuring that rents remaincompetitive and that units at the property do not sit vacant. YieldStar’s algorithm helps its
customers effectively calibrate their response to inflationary pressures to mitigate the risk ofpricing out renters and inadvertently depressing revenues. In a softening market, YieldStar will
identify the slowing internal demand velocity and may recommend lower prices to maintain higher
occupancy.
Recent media coverage of YieldStar based on the aforementioned ProPublica article has
focused on the use of data about other properties, allegedly as part of the process of recommending
rent prices. These reports badly distort and overstate the role that non-public data about otherproperties plays in YieldStar’s algorithm, while also misunderstanding the level of visibility that
YieldStar provides to its customers about such data. To illustrate this point more clearly, we
describe in more granular detail below the building blocks that go into YieldStar’s algorithm, theThe Honorable Elizabeth Warren
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December 19, 2022
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outputs that apartment providers actually can see when they use the platform, and the role, if any,of data about other properties in each step of the process.
Asset Strategy. YieldStar customers begin their decision-making about rent setting bydefining their individual asset strategy for the subject property. Asset strategies are unique to eachcustomer and to each particular property and may depend, for example, on where the customer isin the lifecycle of ownership. For example, a YieldStar customer planning renovations at aproperty may need to accept a lower occupancy to allow renovations to proceed on vacant units,
while an owner seeking to refinance a newer property may have little to no tolerance for vacancies
beyond what is necessary for normal resident turnover activity. YieldStar allows customers to set
their preferences so that the algorithm is calibrated to achieve those individualized objectives.
Importantly, neither RealPage nor the YieldStar software ever shares one customer’s asset strategy
with any other RealPage customers. Similarly, YieldStar does not factor any customer’s selectedasset strategies into its calculation of recommended prices for other YieldStar customers.
Property-Specific Data. YieldStar’s algorithm utilizes a significant amount of data related
to the customer’s specific property. Relevant inputs include the name, location, and asset type of
the property, the number of bedrooms and bathrooms, square footage, building numbers, unit
numbers, floor plan names, and make ready dates.
Most critically, the YieldStar algorithm incorporates historical and current data regarding
the subject property’s lease history. The historical data typically includes
This historical data is used to build the demand and price elasticity
curves for each floor plan at that specific property. For example,
are used toproject the level of demand the property can expect in the future.
areused to calculate the average number of vacant days for that particular floor plan, and the effective
net rent reflects the rent that was actually agreed to by the resident and apartment provider,accounting for various factors like up-front or amortized signing incentives.
In addition to historical data, YieldStar incorporates afeed of data from thecustomer’s own property,
that establish
the property’s current supply and the rent that residents have agreed to pay.
YieldStar uses internal data provided by the customer about its own property to recommend
whether price adjustments should be made to some or all of the floor plans in that property to help
meet the customer’s strategic goals. If, for example, a customer is failing to achieve leasing or
renewal activity for a particular floor plan, then YieldStar may recommend that a downward priceadjustment is warranted. Put another way, the primary driver of price adjustments is the customer’sThe Honorable Elizabeth Warren
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Page 8internal data from the subject property showing whether the property is failing, meeting, or
exceeding the customer’s own unique objectives—not data about other properties that may be
executing entirely different strategies.
Data About Other Properties. Often YieldStar recommends no price adjustment at all.
However, if a price adjustment is recommended to balance supply and expected demand for thecustomer’s floor plan to meet the customer’s strategic objectives, YieldStar will consider external
data about rents for equivalent floor plans at a previously established set of other properties in thearea. This produces a range (high end and low end) of rents that have been historically charged(or have been recently asked) for the particular floor plan being priced. All rents are anonymized
and averaged, with outlier rents eliminated from consideration.

With respect to generating a range of rents, YieldStar relies on a variety of data sources forrents at other properties, including public sources, such as rents listed on apartment provider
websites. While rents for other properties that are used to generate a range are gathered largely
from publicly available information, YieldStar supplements these rents with data, where available,on achieved effective rents based on executed leases. It is also important to note, however, that
executed rent data is not always available for the set of properties in a given customer’s immediatearea and even where it is, as detailed below, it is anonymized and aggregated so that a customer
does not have visibility through YieldStar into the pricing of other specific properties. In fact, allof the rents in the range provided by YieldStar to its customer are anonymized and aggregated—the customer receives no property-specific information.
Further, as part of this analysis, RealPage does not consider unit availability, vacancy rates,or upcoming supply of any floor plan at any of the other properties in any of its revenue

The Honorable Elizabeth Warren
The Honorable Tina Smith
The Honorable Bernie Sanders
The Honorable Edward J. Markey
December 19, 2022
Page 9management products, including YieldStar. It also does not consider the recommended pricing
provided by YieldStar at any other property. The only data about other properties that is used togenerate the blended market range are the rents either publicly advertised or, in some instances,
actually and previously executed.
Recommendations. YieldStar utilizes the described inputs (largely data specific to thecustomer’s property and only supplemented by aggregated data about other properties if there is arecommendation to lower or increase rents) to generate a pricing recommendation for each floor
plan at the customer’s subject property. The user interface that conveys YieldStar’s pricing
recommendation focuses on internal supply and demand balance. The customer’s users decide
how to use the recommendation, including whether to accept the recommendation, and respondthrough the user interface. Applying their own discretion, users can either manually accept therecommendations or they can schedule the system to automatically accept recommendations
within various desired parameters that they themselves select. If they choose to reject therecommendation, then the user can choose to maintain the current pricing or override the rate andmanually input their preferred price.
YieldStar customers may toggle to a separate screen to learn where their floor plan rents
fit within the identified range. The screen does not identify which other properties’ rents were
included, nor does it separately break out the advertised (publicly available) or achieved rent pricesof the other properties. There is no way for a customer to deconstruct the aggregated information
presented to obtain visibility into the rents charged by another property.
In conclusion, contrary to allegations in recent media coverage, YieldStar does not—under
any circumstances—disclose non-public data to its customers about other properties, nor may a
customer infer information about other properties from the data provided by YieldStar.
IV.

YIELDSTAR’S ROLE IN THE RENTAL MARKET

In addition to inaccurately portraying the scope, use, application, and visibility of data
about properties other than the customer’s specific property in RealPage revenue management
software, the ProPublica article and related media coverage have also introduced a number ofother misconceptions concerning how YieldStar works and its impact on rental markets. We
address some of these inaccuracies and misconceptions below.
YieldStar customers are not obligated to accept the software’s pricing recommendations.
YieldStar customers are under no obligation—contractually or otherwise—to follow the pricing
recommendations generated by YieldStar software. Customers are free to follow, modify, or ignore
the recommendations as they see fit. It is ultimately up to each customer to execute the pricing

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The Honorable Tina Smith
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strategy that it determines is appropriate for its property, and YieldStar rent price recommendations
are intended only as decision support for the customer’s ultimate individual pricing decisions.
YieldStar offers apartment providers and prospective residents more options to reach an
agreement, aids compliance with Fair Housing laws, and affords prospective residents
confidence that they have access to the best pricing available to everyone. RealPage recommends
that YieldStar customers use pricing that is transparent to prospective residents rather thanpotentially engaging in price discrimination that may result in providing different individuals withdifferent pricing for the same apartment unit. This helps protect both apartment providers andprospective residents, and encourages compliance with Fair Housing rules, which exist to ensurethat everyone (regardless of demographics) has access to the same rental rates for the same unit on
the same day. Obviously, it is up to each customer to decide for itself whether to adopt thisrecommendation.
Revenue management products like YieldStar helped pioneer the availability of “matrix
pricing,” which offers renters increased options and heightened flexibility to select a preferredlease term and associated rate that meets their individual needs. Before matrix pricing wasavailable, many renters were locked into rigid start and move-out dates and fixed 12-month leaseterms, because it was difficult for apartment providers to assess what complex alternative terms
would mean for the property’s overall occupancy rates, costs, and revenues. Renters needing more
flexible lease terms would therefore be stuck paying for extra (unneeded) months or face fees andother charges for ending the lease early. Matrix pricing allows much more flexibility, like a uniquemove-in date and non-standard rental term, and the corresponding rent price will be calculated
taking those factors into account. This flexibility benefits prospective residents and protects
apartment providers, who can avoid vacancy risk when a renter moves out early. Matrix pricing
also helps prospective residents quickly identify the lowest possible rent.
YieldStar is not designed to maximize rents; its purpose is to manage overall revenues at
a property. The ProPublica article’s effort to portray YieldStar’s purpose as solely focused onincreasing rent is belied by the model itself; a fundamental tenet of YieldStar’s dynamic pricing
model is that it makes recommendations in all directions: higher, lower, or at the current rent price.
If, for example, the model detects softening in the subject property’s demand relative to theavailable supply, YieldStar will often recommend reducing rents to minimize vacancies andpreserve property-wide revenues. The data also does not support the assertion that YieldStar
uniformly pushes rents higher.

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The Honorable Tina Smith
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Outperforming the market does not mean higher rent growth. Some have conflated a 3%
outperformance of the market by YieldStar users in terms of revenues with a 3% increase in rental
rates. Here, it is critical to draw a distinction between a property’s “revenue optimization,” which
YieldStar supports, and “rent maximization,” which YieldStar does not. Rent maximization—
which is not the goal of revenue management software—entails setting the rent of an individual
apartment unit at the highest possible price at which that particular unit will rent. Revenue
optimization, by contrast, entails setting optimal rents for each floor plan to minimize vacancy andmaximize revenues given market conditions. YieldStar’s focus on revenue optimization, as
opposed to rent maximization, is critical to its customers’ success.
Outperformance can even occur during an economic downturn when rental rates andrevenues are declining. YieldStar is designed to enable its customers to outperform the market insuch conditions by preserving overall revenues better than the average apartment provider. By
cutting rents faster due to early indicators of softness in demand, customers may be able to fill
their available units and keep occupancy higher through the downturn, generating more cash flow
and therefore better revenue performance. Crucially, “outperforming the market” in this context
may still mean revenues (and rents) are declining; however, they would be declining at a lower
rate than the market writ large.
YieldStar does not use any personal or demographic data to generate rent
recommendations. YieldStar does not use or consider in its algorithm any personal or
demographic data concerning prospective or current residents. When YieldStar generates a pricing
recommendation, it does not know who is seeking to rent the apartment, nor does it know thedemographics of residents at other properties that might be considered in generating therecommendation. YieldStar was purposely designed in this way to reduce bias in rental markets,and to assist apartment providers in meeting their obligations under the Fair Housing Act andsimilar state and local fair housing laws.
YieldStar never recommends withholding units from inventory. Unless an apartment
provider affirmatively removes a unit from its available inventory (e.g., due to damages or toenable renovations), YieldStar will recommend a price for each unit at the property. More
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The Honorable Tina Smith
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importantly, the supposition by some that YieldStar pushes its customers towards excessive
vacancy rates is wrong and belied by the data. For the last five years, YieldStar properties averaged
2.1% lower vacancy rates than properties that have two or more units according to data reportedby the U.S. Census Bureau. Those vacancy rates for YieldStar properties were lower than thenational averages for four out of the five years when compared to “1 unit” and for each of the five
years for the other two benchmarks.

YieldStar does not recommend prices for the vast majority of rentals in the United States.
Fewer thancustomers in the United States currently use YieldStar at their properties.
Nationally, YieldStar’s share of total rental units is less thanand, even including all three of
its revenue management products, RealPage’s share is less than.

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The Honorable Tina Smith
The Honorable Bernie Sanders
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Similarly, the MSAs where YieldStar
has the highest penetration have not seen inflated vacancy rates. For example, in 2021, the averagevacancy rate for customers in YieldStar’s Top 25 MSAs averaged just—significantly lower
than the national average rental vacancy rate of 6.1% during the same period.9
V.

CONCLUSION

On behalf of RealPage, we appreciate the opportunity to respond to your request andprovide information about YieldStar and the role of revenue management software in U.S. rental
housing. While RealPage shares the concern you set forth in your Letter about the lack ofaffordable housing that has existed in the U.S. for decades, it is the severe shortage in supply thathas triggered rising housing costs—not the use of revenue management software, which iscommonly used in many industries to help manage inventory. As the information set forth above
demonstrates, YieldStar is not designed to maximize rents, but to manage overall revenues at aproperty, given the supply and demand for apartments and market conditions. Despite efforts toportray YieldStar as encouraging vacancies in rental housing, YieldStar never recommends
withholding units from inventory and its average vacancy rate in its top 25 MSAs in 2021 was lessthan the national average.
With respect to this response, production of this information is not intended to constitute a
waiver of the attorney-client, attorney work product, or any other applicable rights or privileges inthis or any other forum. RealPage expressly reserves its rights in this regard. Information anddata provided today may contain confidential, sensitive, or proprietary information. Accordingly,
RealPage respectfully requests that such information be kept confidential by you and your staff.
Notwithstanding our request that such information be kept confidential, we would ask that yourstaff provide us with reasonable notice and an opportunity to be heard before you disclose any
such information or data to any third parties.

6

7
8

9

See United States Census Bureau, Quarterly Residential Vacancies and Homeownership, Third Quarter
2022 (Nov. 2, 2022), https://www.census.gov/housing/hvs/files/currenthvspress.pdf.

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The Honorable Tina Smith
The Honorable Bernie Sanders
The Honorable Edward J. Markey
December 19, 2022
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We hope the information presented in this response helps to clarify how YieldStar works
and the benefits of revenue management. RealPage is committed to continuing its support for
efforts to address the shortage in low-income and affordable housing. Please do not hesitate tocontact me if you have further questions.
Sincerely,

Karen Elizabeth Christian