A Landlord Empire Built on Old Homes and Missing Disclosures

☠️ Lead poisoning does not announce itself. It builds silently in the bodies of young children, stealing IQ points, shortening attention spans, triggering learning disabilities, and causing behavioral problems that can follow a child for life. Congress understood this when it passed the Residential Lead-Based Paint Hazard Reduction Act in 1992, mandating that landlords warn tenants before they sign leases in pre-1978 housing, where lead paint was common and legal.

Homeworks Management Corporation, HomeWorks Funding Group II, and HomeWorks Realty, LLC chose to ignore those warnings. According to a 2026 federal consent order signed by company managers and the U.S. Environmental Protection Agency, these three related entities managed and leased a portfolio of residential properties across South Bend and Mishawaka, Indiana, all built between 1895 and 1954. For years, they handed tenants lease agreements that omitted the federally required lead hazard warnings, failed to disclose known or potential lead paint risks, and conducted renovation work without certified lead-safe contractors or proper documentation.

The EPA documented 98 separate violations. The settlement penalty totals $25,000.

Inside the Allegations: What Homeworks Failed to Do

The EPA’s enforcement order catalogs five distinct categories of disclosure failures, each representing a separate legal duty that these companies systematically skipped.

No Lead Warning Statements in Seven Leases

Federal law requires every lease for pre-1978 housing to include a specific lead warning statement. Homeworks omitted this warning entirely from seven lease agreements, including several covering homes built as far back as 1895 and 1900. Tenants who moved into these homes received no written notice that the walls around them could harbor a neurotoxin.

Eight Leases With No Disclosure of Known Hazards

Beyond the warning statement, landlords must also affirmatively state what they know or do not know about lead paint in the property. Homeworks failed to include any such disclosure in eight lease contracts. In at least one case, the company had already received a St. Joseph County Health Department risk assessment flagging lead-based paint components at one of its properties (718 Altgeld Street, built in 1920). The EPA’s order notes that renovation work at that address included “Interim Controls/Repairs on Lead-Based Paint Components/Hazards following a St. Joseph County Health Department Risk Assessment.” That assessment existed. Tenants signing leases did not receive the information it contained.

Nineteen Leases Missing Hazard Records or Statements

Landlords must also provide tenants with a list of any existing lead paint inspection reports, risk assessments, or hazard records, or state plainly that no such records exist. Homeworks skipped this requirement in 19 out of 27 leases. In other words, the overwhelming majority of their tenants received no information about whether any prior testing had ever occurred in their home.

Twenty Leases Missing Tenant Acknowledgment Statements

The law requires tenants to sign a statement confirming they received the lead hazard information pamphlet. Homeworks failed to obtain this acknowledgment in 20 leases. That pamphlet, titled “Renovate Right,” exists precisely to give families information they need to protect children from lead exposure. Homeworks tenants, many renting homes built before World War I, never confirmed receipt of it in their lease paperwork.

Sixteen Leases Missing Required Signatures

Even the basic requirement that both landlord and tenant sign and date the disclosure certifications went unmet in 16 leases. The absence of signatures is not a technicality. It is evidence that the disclosure process never happened at all.

Six Leases With No Retained Records

Federal regulations require landlords to keep copies of completed lead disclosure paperwork for at least three years. For six leases, Homeworks failed to retain those records. When the EPA came asking in May 2021, key documentation was simply gone.

Renovation Violations: Certified Contractors Were Never Hired

🔨 The EPA’s Renovation, Repair, and Painting Rule exists because disturbing old paint during construction work releases lead dust, one of the most common routes of childhood lead poisoning. Certified renovators follow containment and cleaning procedures specifically designed to prevent that contamination from spreading.

Homeworks directed workers to perform seven renovation projects across its properties between 2017 and 2021, including painting, window replacements, and basement scraping at homes built between 1900 and 1950. According to the consent order, the company was never certified as a renovation firm by the EPA during any of these projects. It assigned no certified renovator to any of the seven jobs. It obtained no written acknowledgment from occupants confirming they received the lead hazard information pamphlet before work began. And it retained none of the required documentation proving that lead-safe work practices had been followed.

Corporate Accountability Fails the Public: The Math of $255 per Violation

💰 The EPA had the legal authority to assess up to $22,263 per violation of the lead disclosure rule and up to $49,722 per day per violation of the renovation safety rules. The total theoretical maximum penalty for 98 documented violations would have run into the millions.

The actual settlement: $25,000. Divided across 98 violations, that works out to roughly $255 per violation.

The consent order notes that the EPA considered Homeworks’ “ability to pay and the effect on Respondents’ ability to continue to do business” when setting the penalty. In other words, the fine was calibrated to keep the company solvent, not to reflect the gravity of the harm. The settlement also contains no admission of wrongdoing on the core factual allegations. Homeworks “neither admits nor denies” the documented violations.

No provision in the consent order requires Homeworks to notify past tenants about the violations. No fund exists to screen children who lived in these properties for lead exposure. No compensatory mechanism reaches the families who rented these homes between 2017 and 2022 while required safety information sat on paper that never made it into their hands.

Environmental and Public Health Risks: What Lead Exposure Actually Does

🧠 The congressional findings embedded in the lead disclosure law, cited directly in the EPA’s enforcement order, put the public health stakes in plain language: lead poisoning afflicts millions of children under the age of six, causing reduced IQ, reading and learning disabilities, impaired hearing, shortened attention spans, hyperactivity, and behavior problems. The ingestion of household dust containing lead from deteriorating or abraded paint is the most common cause.

Every property in Homeworks’ portfolio was built before 1978, the year the federal government banned lead-based paint in residential housing. The oldest properties date to 1895 and 1900. These homes carry a presumption of lead paint presence simply by virtue of their age. The disclosure rules exist precisely because old housing stock in American cities like South Bend disproportionately houses lower-income families and families of color, the same communities that already face elevated environmental health burdens.

When a company skips the lead warning, fails to document renovation safety procedures, and withholds hazard records, it does not just break the law. It removes the only mechanism a family has to make an informed decision about the home where their children eat, sleep, and play.

Community Impact: South Bend’s Old Housing Stock and Vulnerable Renters

🏘️ South Bend, Indiana carries the legacy of an older industrial city: a dense inventory of pre-war housing, high rental rates among working families, and a long history of economic strain following industrial decline. The Homeworks properties span some of the city’s older residential neighborhoods and a range of housing types, from single-family homes to multi-family buildings, many of them over a century old.

The tenants who signed leases with Homeworks entities between 2017 and 2022 were not wealthy buyers with lawyers reviewing their contracts. They were renters relying on a housing system that requires landlords to follow disclosure rules because most renters lack the independent resources to commission their own lead paint inspections. The entire regulatory framework assumes good-faith compliance by landlords. When that compliance evaporates, renters, especially families with young children, absorb the risk.

Three of the affected properties operated under land contracts, a financing arrangement common in lower-income communities that blurs the line between renting and buying while often providing buyers with fewer consumer protections than either a traditional lease or a conventional mortgage. These properties still carried the lead disclosure obligations, and Homeworks failed to meet them.

Profiting from Complexity: A Three-Entity Structure with One Address

🏢 The EPA’s consent order names three separate legal entities as respondents: Homeworks Management Corporation, HomeWorks Funding Group II, and HomeWorks Realty, LLC. All three share a single business address at 1920 Ridgedale Road, South Bend, Indiana. All three were party to the same violations across the same portfolio of properties. Managers Christy Lewis and Ken Mensik signed the consent order on behalf of all three entities on the same date.

The multi-entity structure is a common feature of real estate operations. It can serve legitimate purposes. It can also distribute liability across corporate lines in ways that complicate enforcement and reduce the practical consequences of any single entity’s misconduct. In this case, the EPA addressed all three as joint respondents, and the $25,000 penalty applies collectively. The settlement does not break down individual entity liability.

How Capitalism Exploits Delay: Years of Non-Compliance Before Action

⏳ The lease violations documented in the consent order begin in 2017. The EPA issued its first request for information in May 2021. The consent agreement was signed in January 2026. The Final Order ratifying the settlement was issued in early 2026.

That timeline means Homeworks operated out of compliance with federal lead disclosure law for at least four years before federal regulators formally contacted the company. It then took nearly five more years from that first contact to a signed settlement. During the entire period between initial violation and final order, the company continued to do business.

Delayed enforcement is a structural gift to the non-compliant. The cost of following the law (training, certification, paperwork) comes upfront. The cost of breaking it (a penalty years later) comes discounted by the time value of money and calibrated to the company’s ability to pay. That math predictably favors non-compliance in the short term, especially for smaller operators weighing overhead costs against enforcement probability.

Legal Minimalism: Compliance as an Option, Not a Standard

The lead disclosure rules Homeworks violated are not obscure regulations buried in obscure regulatory guidance. They are the core operational requirements of managing rental housing in pre-1978 stock. Every lease. Every renovation. Every time. The required pamphlet is titled “Renovate Right.” The required disclosures fit on a single attachment.

The EPA’s consent order reveals a pattern that goes beyond an isolated oversight. Seven of the 27 leases lacked a lead warning statement. Nineteen lacked the required hazard record list. All seven renovation projects lacked certified contractors. All seven lacked tenant pamphlet acknowledgments. All seven lacked required documentation. This is not a filing error. This is an operational posture that treated federal consumer safety requirements as optional paperwork.

Corporate Accountability and Pathways for Reform

📋 The Homeworks case illustrates several specific pressure points where reform could close the gap between legal requirement and actual protection.

Tiered Penalties Based on Portfolio Size and Violation Rate

Current penalty calculations weigh the violator’s ability to pay, which structurally means larger operators face smaller proportional fines than the statute authorizes. A reformed penalty structure would calculate minimums as a percentage of revenue or portfolio value, ensuring that the fine reflects the scale of the operation that benefited from non-compliance.

Mandatory Tenant Notification Upon Settlement

When a landlord settles an enforcement action for lead disclosure violations, the settlement should automatically require outreach to past and current tenants in the affected properties. Families who lived in these homes between 2017 and 2022 may have children who should be screened for lead exposure. The current consent order contains no such requirement.

Public Registry of Lead Disclosure Violations

Enforcement orders are public documents, but they require active effort to locate. A searchable public registry linking property addresses to documented lead disclosure violations would allow prospective renters to check a property’s compliance history before signing a lease.

Stronger Whistleblower Protections for Tenants Who Report

Tenants who notice renovation work in old housing and suspect lead safety protocols are not being followed face a power imbalance when considering whether to report. Strengthening retaliation protections for tenants who report EPA lead safety violations would lower the barrier to enforcement referrals from the ground level.

Conclusion: The Human Cost Behind the Docket Number

EPA Docket No. TSCA-05-2026-0011 is a 29-page administrative document. It lists addresses, work order numbers, regulatory citations, and a payment amount. What it does not list are the names of the families who moved into homes on South Bend’s older streets between 2017 and 2022 and signed leases that stripped them of their right to know what was inside the walls.

The lead disclosure rules exist because Congress recognized that information asymmetry in housing markets costs children their cognitive potential. A landlord knows the property. A renter knows only what the landlord chooses to disclose. When a company like Homeworks Management Corporation removes that disclosure for 27 leases across nearly five years, it does not create a technical violation. It creates a window of preventable harm that the $25,000 settlement does nothing to close.

The case will not make national headlines. It does not involve a Fortune 500 company or a celebrity executive. It involves a mid-sized property management operation in an Indiana city, managing old houses, and a federal enforcement system that moved slowly, settled cheaply, and required nothing for the families most directly affected. That is not an anomaly in American housing enforcement. That is the baseline.

Frivolous or Serious: An Assessment of This Enforcement Action

This enforcement action is serious. The EPA’s consent order rests on documented lease agreements, work order records, and regulatory requirements with clear statutory foundations. The violations across all five disclosure categories and all four renovation rule categories are consistent, numerous, and well-established in the record. The company’s own document submissions, provided to the EPA across multiple responses between 2021 and 2023, formed the factual basis for the violations alleged.

The question this case raises is not whether the action is legitimate. It plainly is. The question is whether the outcome matches the seriousness of the conduct. A $25,000 penalty for 98 violations, with no admission of wrongdoing and no tenant remediation requirement, resolves the government’s administrative case. It does not restore what was taken from the families who deserved, and never received, a simple piece of paper telling them their home might contain lead.