The missing paper trail came before the lease signatures

Lead disclosure rules are built around timing. For housing constructed before 1978, required information must reach a prospective tenant before that person is obligated under a lease. The point is not simply to keep a document somewhere in a management office. The warning and disclosures are supposed to inform the tenant’s decision.

According to the EPA’s September 2026 settlement, Electric City acted as an agent offering leases for four qualifying homes in Anderson, South Carolina. After inspecting the company’s business and reviewing records, the agency said Electric City could not document two required parts of the leasing process.

1. Provide the informationThe tenant must receive an EPA-approved lead hazard pamphlet before becoming obligated under the lease.
2. Put warnings in the leaseThe contract must contain or attach the prescribed warning and disclosures about known hazards and available records.
3. Record tenant receiptThe lease must include a tenant statement affirming receipt of the required information and pamphlet.

“Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly.” Required Lead Warning Statement quoted in the EPA agreement

The required statement continues by warning that lead exposure is especially harmful to young children and pregnant women. The settlement does not say those groups occupied the four properties. It explains why federal law requires the warning before a pre-1978 rental contract takes effect.

Four homes, two categories of alleged failure

The EPA identified four leases signed during 2024 and 2025. Every property was built before 1978. The agency alleged that the contracts lacked the required Lead Warning Statement and the tenant acknowledgment confirming receipt of disclosures, records information, and the lead hazard pamphlet.

An inspection turned lease files into an enforcement case

The proceeding began with a records inspection, not with a reported poisoning case. The supplied order identifies no tenant complaint, medical result, environmental test, or finding that lead paint was present in any of the homes.

1. December 10, 2025An EPA inspector visited Electric City’s Anderson place of business and obtained records to evaluate compliance with federal lead disclosure rules.
2. February 3, 2026Electric City submitted additional records for EPA review. The agency later said the company still could not provide the required documentation for the four leases.
3. September 28, 2026The EPA filed the consent agreement and final order, making its terms effective and concluding the administrative proceeding.

Property managers can fall within the regulation’s definition of an agent. Under the rules cited by the EPA, an agent must inform the property owner of the disclosure obligations and ensure the owner performs the required activities, or personally ensure compliance. That structure prevents a management arrangement from becoming a gap in responsibility.

What the order establishes, and what it does not

The final order approved and incorporated the consent agreement. Electric City agreed to the penalty, accepted the settlement conditions, waived its right to contest the alleged violations, and waived an appeal. The company also acknowledged that the agreement counts as an enforcement action when the EPA considers its compliance history in a future case.

The distinction matters. An administrative settlement can impose a real penalty and binding obligations without becoming a factual admission. It can also document a compliance breakdown without proving that the risk warned about actually materialized.

The tenant consequence is an information gap

On the supplied evidence, the clearest consequence is not a documented medical injury. It is the absence of records showing that tenants received federally required information at the point when it could inform their decision to rent.

A warning statement tells tenants why the age of a home matters. A disclosure identifies what the owner or agent knows. A list of records tells the tenant whether reports exist. The acknowledgment creates a traceable record that those steps happened before the lease became binding.

The EPA alleged that the required steps were not completed. Electric City did not admit that allegation. Either way, the files reviewed by the agency did not provide the documentation the regulation demands, leaving the record unable to demonstrate that the four tenants received those protections on time.