Six leases, and no file that could prove the warning was there

The leases covered homes in Columbia and Sumter built decades before the federal government stopped allowing lead paint for residential consumer use. The newest property on EPA’s list was built in 1969. The oldest dated to 1931.

For housing built before 1978, federal rules require landlords and their agents to give prospective renters specific information before they become bound by a lease. The records are meant to show that the warning happened at the right time, that known hazards and available reports were disclosed, and that the parties acknowledged the information.

EPA’s consent agreement says Empire Property Management Group, LLC could not provide records documenting that the required information had been attached to or included in each of the six leases. EPA further determined that the company did not retain completed attachments or contracts containing that information for at least three years.

What renters were supposed to receive before signing

The disclosure rule does not require a landlord to claim that every older home contains lead. It requires a standardized warning, disclosure of known information, delivery of available reports and a paper trail showing what the renter received.

1. Disclose known informationIdentify known lead-based paint or hazards and provide available reports and records.
2. Provide the warning materialGive the renter the lead hazard information pamphlet and place required warning language in or with the lease.
3. Record acknowledgmentsInclude statements and signatures showing receipt, accuracy and the agent’s compliance duty.
4. Keep the completed fileRetain the lease or disclosure attachment for no less than three years from the start of the tenancy.

Housing built before 1978 may contain lead-based paint.First sentence of the required Lead Warning Statement quoted in the consent agreement, paragraph 13

That sequence matters because disclosure after a lease is signed is not the same as disclosure before the renter is obligated. It also explains why record retention is part of the rule rather than an optional administrative task. Without the completed file, regulators may be unable to verify what information was delivered and when.

The six properties in EPA’s record review

The leases were entered into between April 2024 and March 2025. EPA classified all six dwellings as target housing subject to the disclosure requirements.

The missing files create uncertainty, not proof of exposure

The immediate consequence established by the order is a breakdown in verifiable disclosure and record retention. The document does not include the underlying lease files, tenant testimony, property inspections for lead, laboratory results or medical records.

That limit matters. A disclosure violation can deny renters reliable information about an older home’s known risks and available reports, but it does not by itself prove that lead paint was present or that a person was harmed.

The company settled without admitting the factual allegations

Disclosure rules depend on a record that survives the lease signing

This case exposes a narrow but consequential weakness in housing oversight. A warning system built around disclosure works only if the information reaches the renter before commitment and if the completed record remains available afterward.

EPA’s order does not answer whether each renter received some verbal warning, whether any of the homes actually contained lead paint, or whether anyone was exposed. What it does say is that the company could not supply the records needed to demonstrate compliance across six older rentals. The settlement closed that enforcement proceeding for $1,100, while leaving those underlying factual questions unanswered.