EPA Says Bundy Couldn’t Document Lead Disclosures for Three Rentals.

Three rental files, covering leases signed in 2022, 2023 and 2025, became the center of a federal lead-disclosure enforcement case. Every home was built before 1978, placing it within the category generally covered by federal disclosure rules for older housing.

According to the consent agreement, Bundy Appraisal & Management acted as an agent offering the properties for lease. After reviewing the company’s records, the Environmental Protection Agency said Bundy could not provide documents or otherwise show that two required statements had been included before the tenants entered their leases.

The first was a statement from the lessor disclosing known lead-based paint or hazards, or stating that the lessor had no knowledge of them. The second was a statement from the lessee acknowledging receipt of the required information.

EPA alleged that the absence of those statements violated federal rules. Bundy settled for $2,845. The company did not admit or deny the factual allegations, but it agreed not to contest the alleged violations and waived its right to appeal the final order.

The warning was supposed to come before the commitment

Federal lead-disclosure rules are structured around timing. For covered housing, the required information belongs in the leasing process before a renter becomes obligated under the contract. The rule does not require an agent to prove that lead paint exists before providing the disclosure. It requires a statement of what the lessor knows, including a declaration of no knowledge when that is the case.

An agent must either ensure that the lessor has completed the required activities or personally ensure compliance. That is why the EPA’s agreement treated Bundy’s role as more than administrative paperwork. As the leasing agent described in the order, it had a duty to ensure that the disclosure requirements were followed.

The enforcement document does not allege that Bundy concealed a known lead hazard. It alleges that the company failed to include the required statements in the three lease contracts. That distinction is essential: one claim concerns an undisclosed known danger, while this case concerns failure to document the prescribed warning and acknowledgment process.

The three leases EPA examined

The order does not name the tenants, describe who lived in the properties, or state whether children were present. It also does not report testing results for paint, dust or blood lead levels. The supplied record therefore cannot support claims that the homes contained lead hazards or that their occupants were exposed.

From inspection to final order

1. June 24, 2025 An EPA inspector visited Bundy’s Port Royal business to evaluate compliance with federal lead-disclosure requirements.
2. June 27, 2025 Bundy submitted records by email for EPA review.
3. September 24, 2026 The respondent’s representative signed the consent agreement, according to the dated signature page in the supplied PDF.
4. September 29, 2026 The document bears an EPA Region 4 filing stamp. The final order states that its terms take effect upon filing.

What tenants lost was a verifiable information trail

The record does not prove that tenants went uninformed. It proves something narrower about the government’s review: Bundy could not produce records or otherwise demonstrate that the required statements were included, and EPA alleged that they were not.

That missing trail still matters. The lessor’s statement tells a prospective tenant whether the owner reports known lead-based paint or has no knowledge of it. The tenant acknowledgment creates a record that the information reached the renter before the lease became binding. Without those items, a regulator cannot verify that the disclosure process occurred at the required time.

The settlement documents an alleged breakdown in the warning process. It does not document a poisoning, a confirmed lead hazard or deliberate concealment.

The distinction protects accuracy without making the paperwork meaningless. Disclosure forms are the evidence that a renter received information before making a housing decision. In this case, the government said the evidence was not there.

Bundy’s response was a settlement, not an admission

The consent agreement contains Bundy’s formal position. For purposes of resolving the proceeding, the company accepted EPA’s jurisdiction, agreed to the civil penalty and consented to the order’s conditions. It neither admitted nor denied the factual allegations in the findings section.

Bundy also waived its right to contest the alleged violations and its right to appeal. By executing the agreement, it certified to the best of its knowledge that it was currently complying with the relevant lead-disclosure requirements. The supplied source contains no separate narrative explanation or defense from the company.

The final order makes the settlement immediately binding upon filing. Full compliance resolves Bundy’s liability for federal civil penalties only for the violations and facts specified in the agreement. The document preserves EPA’s authority to pursue other relief where legally appropriate.

What the order requires

• Payment of the $2,845 civil penalty within 30 days of the effective date.
• Compliance with the consent agreement and applicable federal lead-disclosure rules.
• Interest, handling charges and potential late-payment penalties if payment is not made on time.
• Continued responsibility under the order even if the company’s legal status or management of the listed properties changes.

The record ends where the health questions begin

Nothing in the agreement answers whether any of the homes contained lead-based paint, whether a tenant received information outside the lease file, or whether anyone faced exposure. Those are material unknowns, not details that can be inferred from an enforcement settlement.

What the record does show is how a housing protection can fail at its most basic checkpoint. If the required statements are absent from the lease file, the government cannot verify that renters received the prescribed warning before signing. The penalty resolves that records-based case. It does not resolve the unanswered questions about the properties themselves.