Two inspections were conducted by EPA, and widespread non-disclosure was found. EPA sent an information request letter (IRL) to get further information, and for some properties disclosure was not done at all. In some of CRM's properties, disclosure was done after both disclosure dates. CRM chose to inspect and test the properties to prove that they were lead -free. Some properties were able to achieve Lead-free status, but some properties did not. CRM is expected to complete disclosure where necessary, and a reduced penalty will be collected.