EvilCorporations.com | Corporate Accountability Project
EPA Enforcement · TSCA Violation · Florida
CIMCO Management Hid Lead Paint Risks from Florida Renters
A property management broker withheld federally required lead hazard disclosures from tenants renting pre-1978 homes, including families with young children, across six South Florida properties.
■ Medium Severity | Federal Consent Agreement & Final Order
TL;DR
CIMCO Management, LLC, a Florida property management broker, repeatedly failed to give renters the federally mandated lead paint disclosures required before signing leases on pre-1978 housing. Six rental properties across Pompano Beach, Dania Beach, Hollywood, Fort Lauderdale, and Miramar were leased without the required documentation, meaning tenants had no idea they could be living with lead-based paint hazards. Lead exposure is particularly dangerous for children under six years old, causing irreversible brain damage and developmental delays. CIMCO violated federal law not once but across six separate transactions, and was fined just $2,500. That is not justice. It is a billing fee.
Demand that regulators increase penalties for lead disclosure violations. A $2,500 fine does not protect a child from a lifetime of neurological harm.
6
Rental properties with missing disclosures
$2,500
Total civil penalty assessed
1924
Oldest property built (Dania Beach)
11
Violations alleged across 2 CFR sections
The Allegations: A Breakdown
Core Allegations: What CIMCO Did
Failure to disclose a known neurotoxin · 6 properties
| 01 | CIMCO Management, LLC leased six pre-1978 residential properties in South Florida without including the federally required agent compliance statement in any of the lease contracts, as mandated by 40 C.F.R. § 745.113(b)(5). | HIGH |
| 02 | For five of those six properties, CIMCO also failed to include the required signatures of the lessor, agent, and lessee certifying awareness of lead paint obligations, violating 40 C.F.R. § 745.113(b)(6). | HIGH |
| 03 | Properties leased without proper disclosures include a home built in 1924 in Dania Beach and a 1951 Hollywood property. These are decades-old structures with substantial potential for lead paint presence throughout their interiors. | HIGH |
| 04 | The violations span lease transactions from July 2023 through June 2024, representing a sustained pattern of noncompliance rather than a one-time oversight. | MED |
| 05 | As the agent of record for each transaction, CIMCO had an affirmative legal duty under federal law to ensure these disclosures occurred. The company did not meet that duty at any of the six properties. | HIGH |
| 06 | When EPA inspectors arrived at CIMCO’s Hollywood, Florida office on May 7, 2024, the required records were not even present. CIMCO had to submit them after the fact, and those records still failed to demonstrate compliance. | MED |
Regulatory Failures: How Oversight Broke Down
Federal law ignored in plain sight
| 01 | Federal lead paint disclosure rules have existed since 1996 under the Residential Lead-Based Paint Hazard Reduction Act of 1992. CIMCO, operating as a licensed real estate broker, had no excuse for ignorance of these requirements. | HIGH |
| 02 | The EPA only discovered these violations through an active inspection. There is no evidence CIMCO self-reported or flagged the deficiencies internally, suggesting no robust compliance program was in place. | MED |
| 03 | The Consent Agreement and Final Order resolves only the specific violations listed. The EPA retains the right to pursue criminal sanctions and additional penalties for any other violations not explicitly covered by this settlement. | MED |
| 04 | A $2,500 civil penalty for six documented violations across a real estate management company represents a regulatory system that treats children’s health as an acceptable cost of doing business. | HIGH |
Public Health and Safety: Who Was Put at Risk
Lead is a neurotoxin with no safe level of exposure in children
| 01 | Lead-based paint disclosure laws exist specifically because lead exposure causes irreversible neurological damage in children under six years old, including learning disabilities, behavioral problems, and lowered IQ. Renters at CIMCO-managed properties were denied the information needed to protect their children. | HIGH |
| 02 | Federal regulations define “target housing” to exclude only housing for the elderly, persons with disabilities, or zero-bedroom units without young children. Every property on CIMCO’s list was open to families with children under six. | HIGH |
| 03 | Without the required EPA pamphlet “Protect Your Family From Lead in Your Home,” tenants had no federally approved information about testing their homes, identifying deteriorating paint, or seeking medical evaluation for their children. | HIGH |
| 04 | The oldest property on the list was built in 1924. Pre-1978 homes, and especially pre-1950 homes, carry the highest concentration and prevalence of lead-based paint. CIMCO’s failure was greatest where the risk was highest. | HIGH |
Corporate Accountability Failures: The Penalty Is the Problem
A $2,500 fine is not a deterrent
| 01 | CIMCO agreed to pay $2,500 total to resolve all six violations. That averages out to $416 per property where tenants were denied their legal right to lead hazard information before signing a lease. | HIGH |
| 02 | Under the terms of the Consent Agreement, CIMCO neither admits nor denies the factual allegations, a standard legal settlement posture that allows the company to avoid any public acknowledgment of wrongdoing. | MED |
| 03 | No individual executives or agents at CIMCO face personal liability or discipline under this settlement. The penalty falls on the LLC alone, insulating decision-makers from accountability. | MED |
| 04 | The settlement explicitly states that full payment of the civil penalty does not affect EPA’s right to pursue injunctive relief or criminal sanctions separately, meaning the $2,500 does not close the legal door on CIMCO entirely. | LOW |
| 05 | This enforcement action will count against CIMCO’s compliance history in any future EPA enforcement proceedings. Whether that deters future violations remains to be seen. | LOW |
Timeline of Events
July 2023
CIMCO Management leases 412 Northwest 16th Avenue, Pompano Beach (built 1963) without required lead disclosure documentation.
Sept. 2023
CIMCO leases 2613 Gulfstream Drive, Miramar (built 1960) without required disclosures or certification signatures.
March 2024
CIMCO leases 7381 Northwest 37th Street, Hollywood (built 1977) in violation of federal lead disclosure requirements.
June 5, 2024
Two properties leased on the same date without compliance: 22 Southeast 10th Terrace, Dania Beach (built 1924) and 1915 Plunkett Street, Unit 4, Hollywood (built 1951).
June 12, 2024
CIMCO leases 1122 Northwest 4th Avenue, Unit 1, Fort Lauderdale (built 1955) without required agent disclosure statement or certification signatures.
May 7, 2024
EPA Region 4 inspector conducts compliance inspection at CIMCO’s Hollywood, Florida office. Required records are not present and must be submitted after the inspection.
2025–2026
EPA reviews submitted records and determines CIMCO failed to comply across all six properties. Enforcement proceedings commence and conclude simultaneously through the Consent Agreement and Final Order.
March 5, 2026
EPA Region 4 Director signs the Consent Agreement and Final Order. CIMCO is ordered to pay $2,500 within 30 days.
Direct Quotes from the Federal Record
QUOTE 1
Scope of the legal obligation CIMCO ignored
Core Allegations
“A lessor of target housing shall disclose to the lessee the presence of any known lead-based paint and/or lead-based paint hazards; provide available records and reports; provide the lessee with a lead hazard information pamphlet; and attach specific disclosure and warning language to the leasing contract before the lessee is obligated under a contract to lease target housing.”
💡 This is the baseline requirement CIMCO failed to meet. Every tenant deserved this protection before they signed anything.
QUOTE 2
The records were not even at the office during inspection
Regulatory Failures
“Respondent advised the inspector that the requested records were not present at the office at that time but would be submitted after the inspection.”
💡 A company managing lead-disclosure-governed properties did not have its compliance records on-site during a federal inspection. This signals a compliance program that did not exist in any meaningful form.
QUOTE 3
What the records revealed after submission
Core Allegations
“The records submitted by Respondent to the EPA did not demonstrate that prior to entering into the leases referenced in Paragraph 21, Respondent had [included the required agent compliance statement or certification signatures].”
💡 Even after being given the opportunity to produce documentation, CIMCO could not demonstrate it had done what the law required. That is not a paperwork error. That is a failure of the entire system CIMCO was obligated to follow.
QUOTE 4
CIMCO’s duty as agent was unambiguous
Regulatory Failures
“Each agent shall ensure compliance with all requirements of 40 C.F.R. Part 745, Subpart F. To ensure compliance, the agent shall inform the lessor of his/her obligations… and ensure that the lessor has performed all activities required… or personally ensure compliance.”
💡 The law gave CIMCO two paths: make sure the landlord did it, or do it yourself. CIMCO did neither, six times.
QUOTE 5
No admission of wrongdoing required
Corporate Accountability Failures
“Respondent neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO.”
💡 CIMCO pays $2,500 and is legally permitted to walk away without ever saying it did anything wrong. Tenants who lived in undisclosed lead hazard environments receive nothing and no acknowledgment.
QUOTE 6
The penalty amount relative to the harm
Corporate Accountability Failures
“Respondent consents to pay a civil penalty… in the amount of TWO THOUSAND, FIVE HUNDRED DOLLARS ($2,500.00).”
💡 Six properties. Eleven violations. Potential exposure of children to one of the most documented neurotoxins in housing history. The price tag: $2,500. That is less than many renters in these same neighborhoods pay monthly just to live in these homes.
QUOTE 7
CIMCO certifies current compliance only at signing
Corporate Accountability Failures
“Respondent certifies to the best of its knowledge that Respondent is currently in compliance with all relevant requirements of 40 C.F.R. Part 745, Subpart F, and the Act.”
💡 CIMCO certifies compliance going forward, with no acknowledgment of what tenants experienced during the period of noncompliance. Future compliance is not the same as accountability for past harm.
QUOTE 8
What the settlement does not resolve
Regulatory Failures
“Full payment of the civil penalty… shall not in any case affect the right of the EPA or the United States to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law.”
💡 The $2,500 closes one door. Many remain open. But criminal prosecution of a property management broker for lead disclosure failures is, historically, vanishingly rare.
Commentary
What exactly did CIMCO Management fail to do?
As a real estate agent managing rental transactions on behalf of property owners, CIMCO was required by federal law to include specific language in every lease contract for pre-1978 housing. That language had to confirm that CIMCO had told the landlord about their lead disclosure obligations and that CIMCO understood its own duty to ensure compliance. CIMCO also had to ensure that all parties, landlord, agent, and tenant, signed and dated the lease contract certifying their awareness of lead paint risks. CIMCO did none of this for six separate rental properties.
Why is lead paint disclosure such a serious legal requirement?
Lead is a neurotoxin that causes permanent brain damage in young children. There is no safe level of lead exposure. Children living in homes with deteriorating lead paint can ingest lead dust through normal hand-to-mouth behavior. The federal disclosure requirement exists so that tenants, especially parents with young children, have the information they need before moving in: whether the landlord knows of any lead hazards, whether any records exist, and how to protect their family. Stripping that information from renters before they sign a lease is not a technical paperwork violation. It is a failure that can alter the trajectory of a child’s life.
Is $2,500 an appropriate penalty for six properties?
No. At roughly $416 per property, this penalty does not come close to reflecting the potential harm. TSCA allows penalties of up to tens of thousands of dollars per violation per day. The maximum penalty assessed here was a fraction of what federal law permits. A fine this small creates a perverse incentive: it is cheaper to settle than to build a compliance program. Until penalties are large enough to exceed the cost of noncompliance, property managers have little financial reason to change their practices.
Who are the actual victims here?
The renters who signed leases at these six properties between July 2023 and June 2024. They signed contracts without the legally required notice that their homes might contain lead-based paint. Many of these homes were built between 1924 and 1963, decades when lead paint was standard and widely used. Families with children under six who lived in these homes had no way of knowing they should request lead testing, take additional precautions, or even consult a doctor. The legal settlement compensates no tenant and provides no medical monitoring for affected children.
Is this kind of violation common in real estate?
Lead paint disclosure violations are a documented, ongoing problem in the rental housing industry, particularly in older urban and suburban markets where pre-1978 housing stock is concentrated. EPA enforcement actions against property managers and brokers are relatively rare given the scale of noncompliance in the market. Most violations go uninspected and unpenalized. CIMCO was caught because an inspector visited its office. Thousands of similar transactions may occur annually without any federal scrutiny.
Does the settlement mean CIMCO admitted wrongdoing?
No. Under the terms of the Consent Agreement, CIMCO neither admits nor denies the factual allegations. This is standard in EPA administrative settlements. It means the company can pay the fine, comply going forward, and never publicly acknowledge that it put tenants at risk. This structure protects companies from civil liability in private lawsuits but leaves tenants without any formal acknowledgment that their rights were violated.
What can I do to prevent this from happening again?
If you are renting a home built before 1978, demand the EPA lead hazard pamphlet “Protect Your Family From Lead in Your Home” before you sign anything. Ask the landlord or property manager directly whether they have any records of lead paint testing or prior hazard disclosures. If they cannot produce the required documentation, you can file a complaint with EPA Region 4 at the contact information listed on the EPA enforcement website. You can also contact your congressional representatives and demand higher civil penalties for lead disclosure violations, funding for targeted lead inspection programs in older rental housing, and mandatory follow-up medical screening for tenants in properties found to be noncompliant. Collective pressure changes policy.
How serious is this case compared to other EPA enforcement actions?
This is a mid-level administrative enforcement action, resolved without litigation through a Consent Agreement. It is not a criminal prosecution, not a class action, and not a case involving documented injuries to specific children. The EPA pursued and concluded this matter quickly, which is a positive outcome compared to cases that drag through years of litigation. However, the penalty amount and the absence of any compensation or notification to affected tenants reflects the structural limitations of administrative enforcement under TSCA for lead disclosure violations. The law allows for much stronger penalties than were applied here.
CIMCO can be reached by calling (954) 929-9990
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