What CIMCO Was Required to Do, and What They Actually Did

Federal law has required lead paint disclosures in pre-1978 rental housing for over three decades. The rules are not complicated. CIMCO violated them anyway, across six separate transactions, spanning more than a year.

• The Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X) established the framework. Any agent or landlord leasing housing built before 1978 must follow the disclosure rules codified at 40 C.F.R. Part 745, Subpart F. Failure to comply is a prohibited act under Section 409 of the Toxic Substances Control Act.
• The required steps are specific: provide tenants with the EPA-approved pamphlet “Protect Your Family From Lead in Your Home” before they sign anything; disclose any known lead paint or lead hazards; attach a written statement to the lease confirming the agent told the landlord about their legal obligations; and get signatures from all parties certifying compliance.
• CIMCO Management, LLC operated as the “agent” in these transactions under the legal definition at 40 C.F.R. § 745.103. That means CIMCO held the specific legal responsibility to ensure every disclosure requirement was met, not just the landlord. They failed on two separate counts across six properties.
• For all six properties, CIMCO’s lease contracts were missing the required agent compliance statement, the written declaration that confirms the agent told the landlord about their legal duties and that the agent accepted their own duty to ensure compliance. This is required under 40 C.F.R. § 745.113(b)(5).
• For five of the six properties, the lease contracts also lacked the required signatures from landlords, agents, and tenants certifying the accuracy of the disclosures. This is required under 40 C.F.R. § 745.113(b)(6).
• The EPA inspected CIMCO’s office at 5650 Stirling Road, Suite 4, Hollywood, Florida 33021 on May 7, 2024. The records were not present at the office. CIMCO submitted them afterward, on multiple dates. The EPA reviewed those submitted records and found the violations.

“The older the building, the longer lead paint had to degrade into dust. Five of CIMCO’s six properties were built before 1965. Tenants signed those leases without a word.”

From First Illegal Lease to $2,500 Fine: A 32-Month Timeline

The violations did not happen overnight. They accumulated across multiple transactions over more than a year, with the EPA’s inspection arriving well after most of the damage was done.

What a $2,500 Fine Cannot Account For

Lead poisoning is not abstract. It is not a regulatory technicality. It is what happens inside a child’s body when they ingest or inhale microscopic particles from deteriorating paint in old housing, and it is irreversible.

There is no safe level of lead exposure for children. None. The CDC and EPA have stated this repeatedly for decades. When lead enters a child’s bloodstream, it crosses the blood-brain barrier. It disrupts the formation of neural connections during the critical window of early development. The damage is permanent. It cannot be undone with therapy, medication, or money.

The specific harms documented by science include lowered IQ, shortened attention spans, impaired executive function, increased impulsivity, and behavioral problems that persist into adulthood. Children with elevated blood lead levels are more likely to struggle in school, more likely to be diagnosed with ADHD, and significantly more likely to enter the criminal justice system. This is not speculation. These are the findings of peer-reviewed research across decades of study.

The five properties built before 1965 are the ones that demand the most attention here. A home built in 1924 in Dania Beach. A home built in 1951 in Hollywood. A home built in 1955 in Fort Lauderdale. A home built in 1960 in Miramar. A home built in 1963 in Pompano Beach. These buildings predate the federal ban on residential lead paint by decades. Lead paint was used heavily and routinely in American construction throughout the first half of the twentieth century. In homes that old, it is not a question of whether lead paint was used. It is a question of what condition it is in right now, today, in 2024, while families are living inside.

When lead paint deteriorates, it does not disappear. It becomes dust. It settles on floors, on windowsills, on door frames. Children touch these surfaces. They put their hands in their mouths. Toddlers who are just learning to crawl and explore move through these spaces at floor level, exactly where lead dust accumulates. The law exists precisely because landlords and property managers cannot be trusted to volunteer this information. Title X was written because the market failed, repeatedly and predictably, to protect the most vulnerable occupants of old housing.

CIMCO Management was the firewall between those families and that risk. Their job, under the law, was to make sure tenants knew what they were walking into. They were required to hand every tenant a federal pamphlet titled “Protect Your Family From Lead in Your Home.” They were required to make their landlord clients acknowledge their obligations in writing. They were required to get signatures certifying that all of this happened. For five of the six properties, those signatures do not exist in the record. For all six, the written agent compliance statement is missing entirely.

The families who signed those leases do not appear anywhere in the consent agreement. There is no mention of whether any of them had children. There is no mention of whether any blood lead testing was offered or conducted. There is no compensation ordered for any tenant. The settlement resolves CIMCO’s legal exposure for these specific violations. It does not restore anything to the people who lived in those homes.

That is the ledger that a $2,500 fine cannot touch.

“Two leases were signed after the EPA inspection. Whatever CIMCO learned from federal investigators showing up at their door, it did not stop them from repeating the same violations within four weeks.”

Directly From the Document: What the Government Found and What CIMCO Agreed To

Every quote below comes verbatim from EPA Docket No. TSCA-04-2026-6102(b), the Consent Agreement and Final Order signed March 9, 2026. Nothing has been paraphrased.

“The records submitted by Respondent to the EPA did not demonstrate that prior to entering into the leases referenced in Paragraph 21, Respondent had: (a) Included as an attachment or within the contract(s) to lease target housing a statement by the agent involved in the transaction to lease target housing that the agent had informed the lessor of the lessor’s obligations, and that the agent was aware of his duty to ensure compliance… for the target housing listed in Paragraph 21(a)-(f); and (b) Included as an attachment or within the contract(s) to lease target housing the signatures of the lessors, agents, and lessees, certifying to the accuracy of their statements, to the best of their knowledge, along with the dates of signature… for the target housing listed in Paragraph 21(b)-(f).”

• This paragraph is the EPA’s core finding of fact. The records CIMCO themselves submitted proved the violations. The compliance documents that should have been in the leases were not there.
• The missing agent compliance statement covers all six properties, meaning every single transaction CIMCO handled in this case lacked the required written confirmation that the property manager told the landlord about lead disclosure obligations.
• The missing signatures cover five of the six properties. Without signatures, there is no certified record that tenants were told about lead hazards before they were legally bound to their leases.

“For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2), 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; (c) consents to the assessment of a civil penalty as stated below; (d) consents to the conditions specified in 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.”

• “Neither admits nor denies the factual allegations” is standard settlement language, but it means no court ever ruled on the facts. CIMCO agreed to pay and move on without any judicial determination of wrongdoing.
• By waiving the right to contest the violations and the right to appeal, CIMCO foreclosed any future legal challenge to what the EPA found. The violations, as alleged, are now the permanent public record.
• CIMCO acknowledged that this settlement counts as enforcement history. Any future violations will be judged against this record.

“Respondent acknowledges that this CAFO constitutes an enforcement action for purposes of considering Respondent’s compliance history in any subsequent enforcement actions.”

• This is significant. If CIMCO is caught violating lead disclosure rules again, regulators can and will point to this settlement as evidence of a pattern. Repeat violations carry higher penalties under TSCA.
• The practical effect: CIMCO now has a federal enforcement record for lead paint disclosure failures. That record is public and permanent.

“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, Subpart F, and the Act.”

• CIMCO certified under this agreement that they are currently compliant as of signing. If that turns out to be false, the EPA reserves the right to revoke the settlement entirely and assess the full penalty for every violation.
• This certification places the compliance burden back on CIMCO and creates legal exposure if future inspections find ongoing violations.

“Pursuant to 40 C.F.R. § 22.18(c), full payment of the civil penalty, as provided in Section VII (Terms of Payment), 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.”

• Paying the $2,500 does not give CIMCO a clean slate for everything. The EPA explicitly reserved the right to pursue injunctive relief, which could include court-ordered operational changes, or criminal sanctions if criminal conduct is later identified.
• This clause is a standard reservation of rights, but it matters: the settlement only covers the specific violations listed. Any other violations, past or future, remain fully prosecutable.

What the Law Promised Tenants vs. What CIMCO Delivered

Who Gets Hurt When Property Managers Skip Lead Disclosures

Public Health

Lead paint disclosure failures in rental housing are a direct public health threat. The families most exposed to this specific failure are not random. They are concentrated in particular communities.

• The six properties span Broward County, Florida cities with significant populations of lower-income renters, including Pompano Beach, Fort Lauderdale, Hollywood, Dania Beach, and Miramar. Renters in these markets typically have less leverage to demand compliance documentation from property managers, and less resources to test their homes independently.
• Children under six years old are the primary victims of lead poisoning from residential paint. The law’s definition of “target housing” explicitly accounts for this: housing is exempted only when no child under six resides there. The absence of disclosed lead hazard information means parents made decisions about where their children would sleep, play, and grow without information the law specifically required them to have.
• Lead poisoning has no cure. Once neurological damage occurs, it is permanent. Children who were exposed during the window between lease signing and any potential future remediation carry that exposure for life. No part of this settlement compensates them for that risk or that harm.
• The property built in 1924 in Dania Beach is a specific concern. A home that old has had one hundred years for lead paint to chip, peel, and degrade into household dust. The EPA’s own research identifies homes built before 1940 as having the highest probability of significant lead hazard presence.

Economic Inequality

Lead paint exposure is not equally distributed across American society. It is a function of wealth, and specifically of who can afford to live in newer housing and who cannot.

• Renters in older housing stock are disproportionately lower-income, people of color, and working-class families. The properties in this case, built between 1924 and 1977, are exactly the kind of affordable older housing that serves these communities. The failure to disclose lead hazards in this housing stock is an environmental justice issue, not just a compliance technicality.
• Testing a home for lead paint costs money. Relocating away from a hazardous rental costs money. Filing formal complaints and navigating EPA enforcement processes requires time, knowledge of the system, and resources that most working renters do not have in abundance. The tenants in these six properties had none of the information they needed to make any of those calculations.
• The penalty CIMCO paid, $2,500, is less than one month’s rent in most of the Florida markets where these properties are located. The financial deterrent is minimal for a property management company operating across multiple units. It does not change the economics of cutting corners on compliance.
• Children with elevated blood lead levels face lifetime economic consequences: reduced educational attainment, lower earning potential, and higher healthcare costs. These costs are borne by the children, their families, and the public systems that support them. They are not borne by CIMCO Management, LLC.

How It Was Supposed to Work vs. What CIMCO Did

What CIMCO Paid Per Affected Family

Who Is Responsible, Who Watches Them, and What You Can Do

The enforcement action is settled. CIMCO Management, LLC operates out of Hollywood, Florida. The following people and bodies hold ongoing accountability over this situation.

The Named Parties on Record

• CIMCO Management, LLC: Respondent. A limited liability company doing business in Florida, managing rental properties including the six identified target housing units. Address of record: 5650 Stirling Road, Suite 4, Hollywood, Florida 33021.
• Adi Gal, Broker Associate, CIMCO Management, LLC: Listed as the respondent’s contact in the Certificate of Service. This is the individual through whom the EPA served the enforcement documents.
• Keriema S. Newman: Director, Enforcement and Compliance Assurance Division, EPA Region 4. Signed as Complainant on behalf of the agency.
• Dwana King: Regional Judicial Officer, EPA Region 4. Signed and issued the Final Order on March 9, 2026.

Regulatory Watchlist

• EPA Region 4 (Atlanta): The enforcement division that brought this case. They are the agency responsible for TSCA lead paint compliance enforcement across Florida and seven other southeastern states. If you are a tenant in a pre-1978 rental in this region and you have not received lead disclosure documents, EPA Region 4 is the filing authority. Contact: R4_Regional_Hearing_Clerk@epa.gov.
• EPA National Lead Program: The program office that oversees all Title X enforcement nationally. They maintain public records of enforcement actions, including this one, and publish guidance for tenants on their rights.
• HUD (Department of Housing and Urban Development): Has parallel lead paint enforcement authority for federally assisted housing and maintains the National Lead-Safe Housing Rule alongside EPA’s Title X regulations.
• Florida Department of Health: The state agency that tracks blood lead levels in children and operates the Florida Healthy Homes program. Parents who believe their child was exposed to lead paint can request blood lead testing through their county health department.
• Florida Department of Business and Professional Regulation (DBPR): Licenses and regulates real estate brokers and property management companies in Florida. Complaints against licensed brokers for failure to meet disclosure obligations can be filed here.

What Tenants and Advocates Can Do Right Now

• If you rented a pre-1978 home managed by CIMCO Management, LLC: Request copies of all your lease documents. Check whether they include a signed lead hazard disclosure form, an agent compliance statement, and signatures from all parties. If those documents are missing or were never provided before you signed, you may have grounds for a complaint with EPA Region 4 or Florida DBPR.
• Request a blood lead test for your child: If your child is under six and has lived in any pre-1978 rental in Broward County without receiving lead hazard documentation, contact the Broward County Health Department to request a blood lead level screening. It is free or low-cost through Medicaid for eligible children.
• Report undisclosed lead hazards to EPA Region 4: Any person can file a complaint through the EPA’s online enforcement tip system. You do not need a lawyer. You do not need to prove the violation yourself. Your complaint can trigger an inspection. The EPA’s TSCA tip line is available at epa.gov/enforcement/report-environmental-violations.
• Connect with housing justice organizations in South Florida: Groups like the Housing Foundation of America (Broward County), Legal Aid Service of Broward County, and Florida Legal Services provide free tenant legal assistance. They can advise whether a civil claim for undisclosed lead exposure is viable in your specific situation.
• Demand higher penalties from your elected officials: $2,500 for six lead disclosure violations is a structurally inadequate deterrent. Contact your U.S. Representative and Senators and demand that Congress increase TSCA civil penalty caps to reflect the actual health costs of lead exposure. The current penalty maximums have not kept pace with inflation or with the documented scale of harm.
• Share this settlement publicly: This enforcement record is public. CIMCO’s name, the property addresses, and the EPA’s findings are all in the public domain. Sharing this information with community members in Pompano Beach, Dania Beach, Hollywood, Fort Lauderdale, and Miramar helps current and prospective tenants make informed decisions about who manages their housing.