On April 22, 2026, the Ohio Supreme Court issued a ruling that most mobile home park operators haven’t heard about yet — but they will.

The court declared that submetering companies operating in mobile home communities are public utilities, subject to regulation by the state’s Public Utilities Commission. One of the largest submetering operators in the country was directly affected. The ruling means that utility markups previously treated as operating income may now be subject to rate review, and tenant consumer protections apply to the full billing relationship.

This isn’t an Ohio-only story. It’s the latest domino in a regulatory chain reaction that’s been accelerating for three years.

The Regulatory Timeline You Need to Know

In January 2025, Minnesota became the first state to ban Ratio Utility Billing Systems (RUBS) entirely for electricity. Ratio Utility Billing — the practice of dividing a master utility bill among residents using a formula — was effectively outlawed for power overnight. Water and gas billing came under strict state mandates, and any administrative markup was prohibited.

Colorado followed with HB 25-1090, restricting RUBS for new construction entirely after July 2027. Arizona’s Attorney General issued consumer alerts warning operators that overbilling could result in fraud liability. Class-action lawsuits targeting RUBS practices are already active in Los Angeles.

Then the Ohio ruling landed.

If you’re still running RUBS in any park, read this carefully.

The states where this regulatory shift has not yet happened are not safe — they’re lagging. California, Washington, and New York all have active or pending RUBS legislation. Federal momentum is also building, with housing advocacy groups pushing for manufactured housing protections at the national level.

What Operators Get Wrong About This Risk

Most operators treat this as a future problem. It isn’t. The AG’s office in Arizona is actively sending warning letters. Minnesota operators who didn’t switch in time are now exposed to billing refund claims. And the Ohio ruling is already being cited in other jurisdictions as precedent.

The second misconception: “We switched to submeters, so we’re fine.” Not necessarily. If your submetering arrangement involves any third-party billing company that marks up utility costs, the Ohio ruling may apply to your operation too, depending on how your state courts interpret it. The legal landscape is shifting under operators’ feet in real time.

According to an AP investigation, nearly 70% of mobile home parks running their own water systems violated safe drinking water rules in the last five years. That’s a compounding liability on top of the billing exposure every operator needs to understand.

The Path Forward: Three Steps to Protect Your Portfolio

Step 1: State-by-State Compliance Audit

Map every park in your portfolio against the current law in its state. The answer is different in Minnesota than in Tennessee. For each park, you need to know: (a) what billing method is currently in use, (b) whether that method is explicitly permitted under current state law, and (c) when the law last changed. If you have more than a handful of parks, this is not a job for memory or a spreadsheet. Build a system.

Step 2: Model the Submeter Conversion Economics

Individual submetering — charging residents based on actual measured usage — is the most legally defensible billing model in every state. Yes, the conversion costs $800–$2,500 per pad, which is real money on a 100-lot park. But run the actual math against your RUBS revenue exposure and potential litigation costs before deciding to wait. In most cases, the economics favor moving sooner rather than later.

At Keel Team, we’ve been running this analysis park-by-park across our portfolio. The number that always surprises operators: the ROI on submeter conversion typically turns positive within 18–24 months when you factor in (a) reduced water waste from leak detection, (b) reduced dispute resolution time, and (c) eliminated legal exposure. The billing investment pays for itself.

Step 3: Adopt Purpose-Built Utility Billing Software

Manual meter reading creates the errors that create disputes that create the complaints that create the AG investigations. Platforms like Yardi’s manufactured housing manager module (launched December 2025), SimpleSubwater, and Synergy Utility Billing are built specifically for mobile home community utility management. They automate meter reading submission, apply state-compliant billing formulas, and create the audit trail documentation you’ll need if you’re ever challenged.

We’ve moved our portfolio to automated billing and the difference is measurable — fewer disputes, faster collections, and documented compliance if it ever matters.

What Operators in Non-Affected States Should Do Right Now

Even if you’re in a state that hasn’t moved on RUBS yet: document everything. Your billing formulas, your resident disclosures, your master utility costs vs. what you bill. The operators who get hurt in the next wave of state actions won’t be the ones doing something deliberately wrong — they’ll be the ones who can’t document that they were doing it right.

The regulatory environment for utility billing in mobile home parks has changed permanently. The question is whether you get ahead of it or get caught by it.

At Keel Team, we’ve spent the last year building out our compliance framework across 50+ communities. We’re not the only operators who have — but we’re in the minority. The window to get ahead of this is still open. But it’s closing, state by state.

If you’re evaluating a mobile home park acquisition and want to understand how we analyze utility billing exposure before we close a deal, our Due Diligence Playbook walks through our full acquisition framework — including the utility audit checklist we run on every deal before we commit.

Andrew Keel is the founder of Keel Team, a manufactured housing community investment and management company with 50+ communities across the Southeast and Midwest. Learn more at keelteam.com.