EPA conducted an on-site Neutral Scheme Random inspection to evaluate the firm's compliance with the Lead-Based Paint Disclosure Rule. Respondent manages 260 units at Hillsborough Garden Apartments in NJ. A review of leases found that some Lessees had not been provided Disclosure, while others were given incomplete Disclosure (i.e., forms not thoroughly/correctly completed). Therefore, an Administrative Complaint was issued seeking compliance and payment of a penalty. After informal settlement discussions, the Respondent produced the missing records, claiming that clerical disorganization among their multiple office locations had prevented them from producing the records at the time of EPA's inspection. In consideration of all records, EPA issued a consent agreement/final order requiring the Respondent to implement a Procedure for Maintenance of Records for their leasing operations, as well as payment of a penalty for failure to produce the requested records at inspection or within a reasonable amount of time.