“Pursuant to Title X, it is a prohibited act under Section 409 of TSCA, 15 U.S.C. § 2689, for any person to fail or refuse to comply with a provision of Title X or any rule or order issued under Title X.”

💡 This establishes that Sound City Realty’s failures were not administrative oversights but violations of federal law with legal consequences

“Lead exposure is especially harmful to young children and pregnant women. Before renting pre-1978 housing, lessors must disclose the presence of lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention.”

💡 The required warning statement explains exactly why these violations endanger vulnerable populations

“The records submitted by Respondent failed to document that prior to entering the leases referenced in Paragraph 33(c) through (f), Respondent had: Provided the lessees with an EPA-approved lead hazard information pamphlet as required by 40 C.F.R. § 745.107(a)(1); Included as an attachment or within the contracts to lease target housing the appropriate Lead Warning Statement as required by 40 C.F.R. § 745.113(b)(1); and Included as an attachment or within the contracts to lease target housing a statement by the lessor disclosing the presence of known lead-based paint.”

💡 This shows the violations were not isolated incidents but a pattern affecting multiple properties

“At the time Respondent offered to perform and/or performed the renovations, Respondent had not obtained ‘firm certification’ as required by 40 C.F.R. §§ 745.81(a)(2)(ii) and 745.89(a)(1).”

💡 Performing renovations without certification means Sound City Realty had no trained staff to prevent lead contamination during construction work

“The term ‘renovation’ is defined at 40 C.F.R. § 745.83, to mean, in part, the modification of any existing structure or portion thereof, that results in the disturbance of painted surfaces… The term renovation includes but is not limited to the following: the removal, modification, or repair of painted surfaces or painted components (e.g., modification of painted doors, surface restoration, window repair, surface preparation activity (such as sanding, scraping, or other such activities that may generate paint dust)).”

💡 These common renovation activities generate lead dust that spreads throughout homes when performed without proper safeguards

“For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2), Respondent: admits that the EPA has jurisdiction over the subject matter alleged in this CAFO; neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO; consents to the assessment of a civil penalty as stated below.”

💡 Sound City Realty pays the fine without admitting it did anything wrong, a common settlement structure that shields companies from accountability

“By executing this CAFO, certifies to the best of its knowledge that Respondent is currently in compliance with all relevant requirements of 40 C.F.R. Part 745, Subparts E and F, and the Act, and that all violations alleged herein, which are neither admitted nor denied, have been corrected.”

💡 The company that violated the law for years now simply promises it is following the rules, with no independent verification required

“Based on a review of Respondent’s records to determine Respondent’s compliance with 40 C.F.R. Part 745, Subpart F, the EPA determined that Respondent entered into contracts to lease the residential dwellings that are target housing (‘the Properties’) at the following locations, on the specified dates listed below: a) 555 North Dupont Avenue, #A6, Madison, Tennessee 37115, Year Built – 1968, lease entered on August 12, 2022; b) 606 Ellen Drive, Unit A, Goodlettsville, Tennessee 37072, Year Built – 1971, lease entered on May 1, 2021; c) 1315 Kermit Drive, Nashville, Tennessee 37217, Year Built – 1947, lease entered on July 1, 2019, and lease renewed on January 8, 2022; d) 316 A Lorna Drive, Nashville, Tennessee 37214, Year Built – 1969, lease entered on May 20, 2022; e) 1731 Dr. DB Todd Jr. Boulevard Nashville, Tennessee 37208, Year Built – 1930, lease entered on October 26, 2022; and f) 265 Sunrise Avenue, Nashville, Tennessee 37211, lease entered on April 29, 2022.”

💡 Six separate properties over three years demonstrates systematic non-compliance, not accidental oversight

“Respondent is assessed a civil penalty of TWENTY-SEVEN THOUSAND, FOUR HUNDRED DOLLARS ($27,400) which shall be paid within thirty (30) days after the Effective Date of this CAFO.”

💡 A penalty under thirty thousand dollars may be less than the cost of compliance across six properties over multiple years

“Penalties paid pursuant to this CAFO shall not be deductible for purposes of federal taxes.”

💡 This provision exists because companies routinely treat fines as ordinary business expenses and write them off their taxes

“In accordance with 40 C.F.R. § 22.18(c), Respondent’s full compliance with this CAFO shall only resolve Respondent’s liability for federal civil penalties for the violations and facts specifically alleged above.”

💡 The settlement resolves only the government’s enforcement action and provides no relief to tenants who were denied required safety information

“Any change in the legal status of Respondent, or change in ownership, partnership, corporate or legal status relating to the company, or changes pertaining to its ownership and/or management of the Properties identified in Paragraph 33, will not in any way alter Respondent’s obligations and responsibilities under this CAFO.”

💡 The company can continue operating immediately with no suspension, no probation, and no enhanced oversight period

“Pursuant to 40 C.F.R. § 745.107(a)(1), the lessor shall provide the lessee with an EPA-approved lead hazard information pamphlet. Such pamphlets include the EPA document entitled Protect Your Family From Lead in Your Home (EPA #747-K-94-001) or an equivalent pamphlet that has been approved for use in that State by EPA.”

💡 This pamphlet contains specific instructions for protecting children from lead exposure that Sound City Realty’s tenants never received