COMPLAINT - The Respondents, the owners and lessors of targert housing properties offered for rent, failed to comply with lead-based paint disclosure requirements of the Residential Lead-Based Paint Hazard Reduction Act of 1992 ( RLBPHA ) , 42 U.S.C. 4851 et seq., and the federal regulations promulgated thereunder and codified a 40 C.F.R. Part 745, Subpart F, in the course of executing tem(10) lease agreements with tenants renting nine (9) different target housing residential dwelling units from the Repsondent.