RESPONDENT FAILED TO COMPLY WITH REQUIREMENTS OF RENOVATION, REPAIR AND PAINTING (RRP) RULE BY FAILING TO OBTAIN INITIAL FIRM CERTIFICATION FROM EPA, OBTAIN A WRITTEN ACKNOWLEDGMENT THAT HOMEOWNES HAD RECEIVED THE RENOVATE RIGHT PAMPHLET PRIO TO RENOVATION ACTIVITIES, RETAIN RECORDS NEEDED TO DEMONSTRATE COMPLIANCE WITH RRP, ASSIGN A CERTIFIED RENOVATOR TO EACH PROJECT, AND PROVIDE HOMEOWNERS WITH THE RENOVATE RIGHT PAMPHLET PRIOR TO RENOVATION ACTIVITIES.