Respondent failed to obtain initial firm certification from EPA, failed to distribute the Renovate Right pamphlet to occupants of the property, failed to establish and maintain records documenting compliance with RRP, and failed to assign a certified renovator when it renovated the subject property. EPA is seeking a penalty and the Respondent's return to compliance. Initial proposed penalty was $65,500. However, Respondent demonstrated an inability to pay the proposed penalty and qualified for a substantially reduced penalty under the Agency's Graduated Penalty Approach Pilot Policy. Respondent has ceased renovation activity.