The Non-Financial Ledger: What $27,400 Cannot Cover

Picture a family moving into a house on Dr. DB Todd Jr. Boulevard in Nashville in late October 2022. The house was built in 1930. It is older than most of their grandparents. The paint on the walls, the window frames, the baseboards, the door casings: all of it predates every modern regulation ever written about lead. They sign the lease. They get the keys. They do not get a single word about lead.

No pamphlet. No warning statement. No box on the lease contract saying the landlord does or does not know about lead-based paint hazards. Nothing. Under federal law, every one of those items was mandatory before they were legally bound to that lease. Under Sound City Realty’s standard operating procedure, none of them existed.

This is how lead poisoning works in America. It does not announce itself. A toddler puts a hand on a windowsill coated in 1940s paint and then puts that hand in their mouth. A pregnant woman breathes dust stirred up during a renovation that the company performing it was not certified to do. Nobody gets a warning because the landlord decided the paperwork was optional.

The 1315 Kermit Drive property in Nashville was built in 1947. A tenant first signed a lease there in July 2019. They renewed it in January 2022. Through both the original lease and the renewal, the EPA found no documentation that an EPA-approved lead hazard pamphlet was provided, no lead warning statement was attached to the contract, and no disclosure of known or unknown lead hazards was made. That is years of living in a pre-1948 home without the legal minimum of information.

The 265 Sunrise Avenue property in Nashville does not even have a recorded construction year in the EPA’s findings. The lease was signed April 29, 2022. The same omissions apply. The company did not know the building year well enough to document it, which is itself a signal about how thoroughly they were tracking their legal obligations.

These are not bureaucratic technicalities. The Lead Warning Statement that Sound City Realty failed to include in its lease contracts contains one sentence that is explicit: “Lead exposure is especially harmful to young children and pregnant women.” That sentence exists because lead poisoning in children causes permanent brain damage, developmental delays, lower IQ, and behavioral disorders. It exists because pregnant women exposed to lead face risks of miscarriage, premature birth, and developmental harm to the fetus. Sound City Realty’s tenants did not receive that sentence. They were kept in the dark so their landlord could skip a process.

The $27,400 fine represents roughly how much a Nashville area landlord collects in rent from two or three units over a single year. It is the cost of doing business, absorbed and forgotten. It does not pay for a single blood lead level test for a child. It does not compensate a family for a developmental disorder that will take decades to manage. It does not undo the years those tenants spent in homes where they had no idea what was on the walls.

Legal Receipts: What the EPA’s Own Documents Prove

The following are direct, verbatim statements pulled from Docket No. TSCA-04-2023-3125(b). These are not allegations by a third party. They are findings accepted as the basis of a federal consent agreement that Sound City Realty signed.

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

CAFO, Section IV, Paragraph 35 — Findings of Facts

• This passage covers four of the six properties: 1315 Kermit Drive, 316A Lorna Drive, 1731 Dr. DB Todd Jr. Boulevard, and 265 Sunrise Avenue. All four leases were executed without the three core disclosure requirements that have been federal law since 1992.
• The phrase “failed to document” is doing legal work here. The company either never gave tenants these materials or never kept records proving it did. Both outcomes are a federal violation. Both outcomes left tenants uninformed about potential lead exposure in their own homes.
• The Lead Warning Statement omitted from these four leases contains the specific sentence: “Lead exposure is especially harmful to young children and pregnant women.” Tenants at all four addresses signed legally binding rental agreements without ever seeing those words.

“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).”

CAFO, Section IV, Paragraph 37 — Findings of Facts

• Sound City Realty was performing and offering renovation work on pre-1978 housing for compensation while operating entirely outside the EPA’s lead-safe renovation certification system. EPA certification for renovation firms exists specifically to ensure that any disturbance of painted surfaces in older housing is done safely, with lead-safe work practices, to protect occupants and workers from lead dust exposure.
• The renovation work occurred between January 2022 and December 2022, meaning the company spent an entire calendar year doing certified-work-required jobs without the certification. Every tenant near any of those renovations during that window had no guarantee that federally mandated lead-safe protocols were being followed.

“Respondent: (a) admits that the EPA has jurisdiction over the subject matter alleged in this CAFO; (b) neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO; (e) waives any right to contest the allegations set forth in Section V (Alleged Violations) of this CAFO; and (f) waives its rights to appeal the Final Order accompanying this CAFO.”

CAFO, Section VI, Paragraph 42 — Stipulations

• This is the legal maneuver that corporations use in regulatory settlements: refuse to admit the facts so no liability is formally established, but simultaneously waive the right to challenge or appeal any of it. The company did not fight back because fighting back would have required engaging with evidence they did not want examined in a contested proceeding.
• The “neither admits nor denies” language means there is no formal record of guilt that can be used in a civil lawsuit by an affected tenant. It is legal insulation purchased alongside the penalty payment.

The above is the legally required Lead Warning Statement text from 40 C.F.R. § 745.113(b)(1). Sound City Realty failed to include it in at least four lease contracts covering pre-1978 properties it managed.

Societal Impact Mapping: Who Pays When Landlords Skip the Paperwork

Public Health

Lead poisoning is not a historical relic. It is an ongoing public health emergency concentrated in pre-1978 rental housing, and the legal disclosure system is one of the few tools tenants have to protect themselves.

• The CDC states there is no safe level of lead exposure in children. The primary pathway in residential settings is lead dust and paint chips from deteriorating or disturbed lead-based paint in older homes, exactly the kind found in properties built in 1930, 1947, 1968, 1969, and 1971 as Sound City Realty managed.
• Sound City Realty performed renovation work across all six properties between January and December 2022 without an EPA renovation firm certification. Renovation work in pre-1978 housing that disturbs painted surfaces generates lead dust. Without certification, there is no federal accountability mechanism ensuring that tenants or their children were protected during or after that work.
• The mandatory EPA pamphlet (“Protect Your Family From Lead in Your Home”) that Sound City Realty failed to provide on four properties tells tenants to look for peeling paint, to keep floors and windowsills clean, and to get their children tested. Tenants who never received it were denied even the most basic preventive information about the homes they were paying to live in.
• Blood lead level testing in children is the only way to catch lead poisoning early enough to limit developmental damage. Tenants who were never warned about lead in their homes had no reason to seek testing. Delayed or missed testing means delayed or missed intervention, which translates directly into worse long-term health outcomes.
• The 1731 Dr. DB Todd Jr. Boulevard property was built in 1930 and leased in October 2022. A structure that old has had nearly a century to accumulate layers of lead paint on virtually every painted surface. The tenant who signed that lease received zero disclosure about this reality.

Economic Inequality

Lead paint violations in rental housing do not distribute equally across income levels. They concentrate in the lower-cost rental stock where lower-income families live, and the disclosure failures documented here reflect a pattern of cost-cutting that extracts rent while withholding legally required information.

• All six properties involved in this enforcement action are located in Nashville and surrounding communities (Madison, Goodlettsville). These are working-class rental markets, not luxury developments. The tenants in these properties are disproportionately lower-income renters who depend on the rental market and have limited ability to walk away from a signed lease or afford private lead testing.
• The cost of complying with federal lead disclosure requirements is functionally zero. The EPA pamphlet is free. Attaching a Lead Warning Statement to a lease costs nothing. Signing a disclosure section costs nothing. Sound City Realty skipped these steps not because they were expensive but because compliance required attention and process discipline that the company did not apply.
• The “neither admits nor denies” settlement structure means no affected tenant can point to this CAFO as an admission of liability in a civil suit. The company paid $27,400 to the federal government and received legal insulation from the tenants it failed to protect. That $27,400 does not reach the families who lived in those homes.
• Children with elevated blood lead levels have higher rates of learning disabilities, lower academic performance, and higher rates of involvement in the criminal justice system, all outcomes linked to increased lifetime economic precarity. The public bears these costs through special education services, healthcare, and social services. Sound City Realty bore none of them.
• Obtaining EPA renovation firm certification and ensuring certified renovators perform the work adds cost and time to renovation projects. Companies that skip certification gain a competitive cost advantage over compliant operators, creating a race to the bottom in which rule-following landlords are undercut by those who externalize compliance costs onto their tenants and the public health system.

The “Cost of a Life” Metric

Federal penalty calculations under TSCA are based on the gravity of the violation, the compliance history of the violator, and the economic benefit gained from noncompliance. Here is what the math looks like in human terms.

What Now? Hold the Line on Lead

Sound City Realty certified in the signed agreement that it is now in compliance with all relevant TSCA requirements. That self-certification deserves scrutiny, not trust. Here is who has the power to apply that scrutiny and what renters can do directly.

Corporate Principals Named in the Record

• Owner Juli Schuman, Sound City Realty, LLC. Contact: juli@soundcityrealty.com | (615) 397-2238.
• Legal Rep Robert J. Notestine III, President/Director, Notestine Law Firm. Contact: bob@notestinelaw.com | (615) 202-5071.

Regulatory Watchlist

• EPA Region 4 (Atlanta): The agency that brought this action. Future violations at Sound City Realty’s properties, or similar landlords across Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee, can be reported to EPA Region 4 directly. Inspector Oyepero Olowu (olowu.oyepero@epa.gov) is the named inspector on this case.
• EPA’s Lead-Based Paint Disclosure and Renovation Complaint Hotline: The EPA accepts complaints about landlords violating lead disclosure rules. File at epa.gov/lead or call the TSCA hotline. Every complaint creates a paper trail that can trigger future inspections.
• Tennessee Department of Environment and Conservation (TDEC): State-level enforcement partner for lead regulations in Tennessee. Can pursue state-level action independent of federal proceedings.
• Tennessee Department of Health: Oversees childhood blood lead level surveillance. If you or a family member rented from Sound City Realty in a pre-1978 property, contact the Tennessee Lead Registry program to request environmental investigation.
• Consumer Financial Protection Bureau (CFPB): While primarily a financial regulator, the CFPB tracks patterns of predatory landlord behavior affecting lower-income renters. Complaints here contribute to broader systemic tracking.
• Department of Justice (DOJ) Civil Rights Division: Lead paint violations that disproportionately impact communities of color may be actionable under the Fair Housing Act. Document and escalate to the DOJ if patterns of discriminatory leasing are present.

Direct Action for Tenants and Community Members

• If you have ever rented a pre-1978 home from Sound City Realty and did not receive a lead hazard pamphlet, a Lead Warning Statement, or a lead hazard disclosure in your lease, document it in writing. Save your lease. Your records may be relevant to future enforcement or private legal action.
• Get tested. The Tennessee Department of Health offers resources for childhood blood lead level testing. If your child lived in any of the six properties named in this action (555 N. Dupont Ave. Madison; 606 Ellen Dr. Goodlettsville; 1315 Kermit Dr. Nashville; 316A Lorna Dr. Nashville; 1731 Dr. DB Todd Jr. Blvd Nashville; 265 Sunrise Ave. Nashville), contact a healthcare provider and request a blood lead level test.
• Connect with tenant organizing groups in Nashville. Organizations like Tennessee Justice Center and Nashville Organized for Action and Hope (NOAH) work on housing rights issues and can provide guidance on lease violations, habitability complaints, and collective action.
• Demand local accountability. The Metropolitan Nashville and Davidson County government has building and housing codes. Contact Metro Codes Enforcement to report lead hazard concerns at specific properties. A local complaint creates a local record separate from the federal case.
• Spread this document. The CAFO is public record. Share it with neighbors, local journalists, and housing advocacy organizations. The “neither admits nor denies” clause insulates Sound City Realty from one form of accountability. Public knowledge is another form entirely.