If you own a mobile home park and you’re using RUBS (Ratio Utility Billing System) or any kind of utility markup to pad your NOI, you need to read this today.

On April 22, 2026, the Ohio Supreme Court issued a unanimous ruling that submetering companies operating inside mobile home communities are public utilities — subject to full state regulation. It wasn’t close. It wasn’t a fringe case. And it’s the clearest signal yet that the regulatory ground beneath mobile home park utility billing is shifting fast.

This isn’t just an Ohio problem. It’s a preview of what’s coming everywhere.

What RUBS Is — And Why It Got So Popular

For years, RUBS has been a standard tool in the mobile home park operator’s toolkit. Here’s how it works: the park gets one master bill from the utility company, then allocates costs across residents based on a formula (number of occupants, square footage, etc.) — often with an administrative markup of 10–20% tacked on.

In the 2015–2022 mobile home park boom, RUBS income was frequently underwritten as stable operating revenue. Some deals were penciled with $40–$70/month per lot in utility billing income. At a 100-lot park, that’s $48,000–$84,000 per year in extra NOI — worth $800,000+ in cap rate-driven value.

The problem: that math was always built on regulatory sand.

The Crackdown Is Here

The Ohio ruling didn’t come out of nowhere. Here’s the trail:

• Minnesota, January 2025: Banned RUBS for electricity; prohibited administrative markups on water and gas
• Colorado: Active restrictions on RUBS practices
• Multiple states: Class-action lawsuits targeting retroactive RUBS refund exposure — some reaching back 3+ years
• Ohio, April 2026: Supreme Court rules submetering companies are public utilities, subject to rate oversight

The common thread in all of these? The “greedy landlord” narrative around mobile home parks gave politicians and attorneys general the political cover they needed to act. And they did.

What This Means for Your Portfolio Right Now

If you own parks in states with RUBS or submetering arrangements, you are carrying undisclosed legal risk on your balance sheet. Here’s what that looks like in practice:

Scenario A — Class action: A tenant attorney files a class action for utility overcharges. Discovery reveals 36 months of RUBS billing. At $50/month per resident in “overcharges,” a 100-lot park faces $1.8M in potential refund exposure before legal fees.

Scenario B — AG investigation: Your state’s AG, feeling political pressure after news coverage of “mobile home park landlords gouging tenants on utilities,” sends an audit letter. You now need outside counsel in a regulatory proceeding.

Scenario C — Deal collapse: You go to sell a park. A sophisticated buyer’s counsel identifies the RUBS exposure during due diligence and either walks or demands a $500K escrow holdback.

None of these are hypothetical. They’re happening.

The Fix: Convert Before You’re Forced To

The good news is that proactive action significantly reduces your exposure. Here’s what we recommend to operators in our network:

• Step 1: Audit every park’s billing model this week. Know exactly what billing structure you have in each park — direct billed, master meter, RUBS, submetering with markup, submetering at cost. Don’t guess. Pull the contracts.
• Step 2: Cross-reference against current state law. What was legal 3 years ago may not be today. Have an attorney in each state where you own parks review your current billing structure.
• Step 3: Convert to individual submetering at cost. This is the gold standard for legal defensibility. Residents pay for exactly what they use, at the rate the utility charges you. No markup, no allocation formula, no exposure.
• Step 4: Communicate proactively with residents. Frame the conversion as a fairness upgrade. “We’ve updated to actual usage billing so every resident pays exactly what they use.” This builds goodwill with the people who live in your community.
• Step 5: Underwrite future acquisitions with zero utility markup income. If a deal only works because of RUBS revenue, the deal doesn’t work. Full stop.

This is exactly the kind of utility compliance issue we cover in detail in our Mobile Home Park Due Diligence Playbook — including how to pull utility records directly from the municipality and benchmark them against industry standards before you close on any deal.

What We Do at Keel Team

At Keel Team, we don’t use RUBS or utility markups in any park we operate. Every resident in our portfolio is billed either directly by the utility company or by individual submetering at actual cost. We made this decision not because we had to, but because it’s the right way to run these communities — and because we saw this regulatory trend coming two years ago.

When we evaluate parks for acquisition, we require 36 months of utility billing records directly from the municipality. We run gallons-per-lot benchmarks (industry standard: 50–80 gallons per lot per day for water). We inspect master meters and main lines. And we never underwrite RUBS income as stable operating cash flow.

The parks that will weather this regulatory wave are the ones run by operators who’ve already made the shift. The ones that will get hurt are the ones still hoping the regulators don’t show up at their door.

Don’t wait. Audit your portfolio today.

Andrew Keel is the founder of Keel Team Real Estate Investments, which owns and operates 50+ mobile home parks across the Southeast and Midwest. Keel Team specializes in affordable housing communities and responsible ownership practices.