Based on a June 3, 2019 EPA inspection in which a number of renovation contracts were collected, EPA determined that the company may have violated the RRP Rule by failing to have RRP firm certification, failure to assign a certified renovator, failure to establish or maintain records documenting compliance, failure to distribute the Renovation Right pamphlet, and failure to post warning signs for a number of renovation jobs. EPA is seeking a penalty and the company's return to and maintenance of compliance. Respondent demonstrated financials to qualify for a reduced penalty under EPA's Graduated Penalty Approach (GPA) Policy.