Respondent violated the Lead Disclosure Rule and the RRP Rule. Based on inspections, on March 15 and 31, 2022, EPA determined that Respondent, between at least January 2020 to March 2022, deprived tenants of important and required lead information when leasing multiple apartment units in both Pennington Court and John J Hyatt developments. Further, EPA determined that Respondent had no understanding of the RRP Rule prior to EPA?s inspections and took no steps to protect tenants during renovations. EPA alleges that between January 2020 and March 2022, Respondent staff performed at least 15 renovations at both developments in violation of the RRP Rule. Respondent claimed an inability to pay and submitted yearly financial audits determining Respondent could only pay a maximum penalty of $170,000. EPA is seeking a penalty with a possible full remittance if certain conditions are met. Respondent has already implemented significant injunctive relief and will maintain compliance.