On January 4, 2017, EPA filed a CAFO against Respondent for alleged violations of the RRP Rule. Respondent failed to obtain firm certification prior to conducting renovation activities in target housing. Respondent also failed to provide homeowner with the required standard lead-based paint information. At the conclusion of the renovation activities, Respondent failed to properly clean the work area. Respondent provided evidence that it was in the process of dissolution and had significantly lower revenues. Based on this information, EPA proposed a reduced penalty of $4,000.