How Cagan Management Group Traded Child Safety for Rent Checks

Cagan Management Group held lead hazard records for some of its properties since at least 2017 and still handed leases to tenants — including families with young children — with no warning, no disclosure form, and no pamphlet explaining that their home could poison their kids.

The Company That Knew — And Said Nothing

Cagan Management Group, Inc. operates out of Skokie and Chicago, Illinois. Between January 2021 and January 2025, Cagan managed residential apartment buildings across Chicago and Evanston — buildings constructed before 1978, meaning they fall under federal law requiring landlords to disclose any known lead-based paint hazards to every incoming tenant.

Federal law on this point is not ambiguous. The Residential Lead-Based Paint Hazard Reduction Act of 1992 requires landlords to hand tenants a written disclosure of any known lead hazards, a list of all inspection records and reports related to lead, a signed statement from the tenant confirming they received that information, and certified signatures from all parties. Every single lease. Every single time. No exceptions for pre-1978 buildings housing children under six.

The EPA began requesting Cagan’s lease and disclosure documents in January 2022. The agency sent follow-up requests in October 2024 and February 2025. What the documents revealed across 31 separate lease transactions at properties spanning the North and South Sides of Chicago was a pattern of systemic failure spanning at least five calendar years.

The Scale of What They Hid

The EPA documented four distinct categories of violations, each representing a separate layer of the disclosure system that Cagan either ignored or actively bypassed. Thirteen violations for failing to disclose known lead hazards in lease agreements. Fifteen violations for failing to attach or reference known lead inspection records and reports. Fourteen violations for omitting the required tenant receipt affirmation. Fourteen violations for missing or unsigned certification statements.

That adds up to 56 documented violations — and those are only the ones the EPA could verify from the documents Cagan itself submitted. The actual number of tenants who moved into these units without receiving legally required safety information could be higher; the enforcement action covers only the transactions that generated paper trails.

The Non-Financial Ledger

What Lead Does to a Child’s Brain

Lead is a neurotoxin. There is no safe level of lead exposure for a child under six years old. When a child ingests or inhales lead dust — from peeling paint, disturbed plaster, or contaminated soil around an old building — it crosses the blood-brain barrier and interferes directly with neurological development. The damage is permanent. No treatment reverses cognitive harm caused by lead poisoning in early childhood.

The symptoms can look like many other things at first: fatigue, irritability, difficulty concentrating in school. Parents often spend months or years chasing diagnoses and specialists before lead poisoning surfaces as the cause. By the time it does, the exposure has already done its work. The window to prevent the harm closed the moment that family signed a lease and moved their child into an undisclosed lead-hazard unit.

Cagan Management Group held records from the Chicago Department of Public Health addressing lead-based paint hazards at some of its properties. One of those records, for a unit at 2048.5 West Chase Avenue, was dated October 21, 2019. The tenant signed a lease for a unit at that same address on June 22, 2023 — nearly four years after Cagan received documented evidence of a lead hazard there. The EPA’s records show Cagan disclosed nothing about it in that lease.

The Betrayal of the Lease

A lease is supposed to be a contract of basic good faith. You pay rent; the landlord provides a safe, habitable space and tells you what they know about it. The federal disclosure law exists specifically because Congress recognized that renters — especially low-income renters in older urban housing stock — cannot independently detect lead hazards. They depend entirely on the landlord’s honesty. Cagan converted that dependency into an opportunity to say nothing and collect checks.

The 31 lease transactions in this enforcement action represent 31 separate moments where a family or individual sat down, signed paperwork, handed over a security deposit, and trusted that the property manager across the table was dealing with them honestly. Cagan’s own records show the company possessed lead hazard documentation for at least 13 of those 31 properties at the time the leases were signed. The tenants got the lease. They did not get the truth.

Five Years of the Same Choice, Made Over and Over

The lease transactions in this case span from March 2020 through February 2025. That is five years. Across that span, Cagan received at least three separate information request letters from the EPA — in January 2022, October 2024, and February 2025 — while the violations continued to accumulate. New leases with the same disclosure failures appear in the record as late as February 2025, even as Cagan was actively responding to federal regulators investigating the exact same conduct.

This is the detail that defines the character of the conduct. These were not accidents. A single missed disclosure form is an oversight. A single property with no attached lead report might be an administrative gap. But 57 violations across 31 properties spanning five years, including violations that continued during an active federal investigation, represent a management policy. The people running those buildings made a choice, repeatedly, to prioritize lease execution over tenant safety.

Legal Receipts

Direct From the Federal Record

“Complainant received records containing information about lead-based paint and/or lead-based paint hazards at target housing from Chicago Department of Public Health addressed to Respondent for several properties, including 2048.5 W. Chase Avenue, Unit 3D dated October 21, 2019.”

— EPA Consent Agreement and Final Order, Paragraph 28. Cagan held a government lead-hazard record for this address since 2019. A tenant signed a lease there in June 2023. No disclosure.

“Respondent included inaccurate or incomplete information, failing to disclose Respondent’s knowledge of the presence of known lead-based paint and/or lead-based paint hazards in the target housing, including the location of the lead-based paint and/or lead-based paint hazards, and the condition of the painted surfaces, either within the contract or as an attachment to the contract.”

— EPA Consent Agreement and Final Order, Paragraph 32. This is the agency’s formal finding that Cagan actively provided false or incomplete information in its lease agreements.

“Respondent failed to include, before the lessee was obligated under a contract to lease the housing, either within the contract or as an attachment to the contract to lease target housing a dated statement by the lessee affirming receipt of the information required by 40 C.F.R. § 745.113(b)(2) and (3) and the Lead Hazard Information Pamphlet.”

— EPA Consent Agreement and Final Order, Paragraph 40. Tenants signed legally binding rent obligations without ever receiving or signing off on lead hazard disclosures.

“EPA has determined that an appropriate civil penalty to settle this action is $99,461. Respondent agrees to pay a civil penalty in the amount of $69,000 (Assessed Penalty) within thirty (30) days after the date the Final Order ratifying this Agreement is filed.”

— EPA Consent Agreement and Final Order, Paragraphs 48–49. The EPA determined $99,461 was appropriate. Cagan paid $69,000 to EPA, with the remaining $30,461 paid to HUD under a parallel agreement.

“The earliest lead record dated October 31, 2017” — for 534 Hinman Avenue, Evanston, IL. A lease was signed at that property on January 13, 2021, with no disclosure of those records.

— EPA Consent Agreement and Final Order, Lead Information Table, Line 22. Cagan had lead documentation for this Evanston property for more than three years before the lease in question was signed.

Societal Impact Mapping

Public Health: The Youngest Tenants Pay the Highest Price

Lead exposure in children under six causes irreversible damage to the developing brain and central nervous system. The federal disclosure law Cagan violated exists because Congress, in 1992, formally recognized this risk and determined that landlords of pre-1978 housing have a non-negotiable duty to warn tenants before they commit to living there. That duty exists precisely because renters cannot see lead paint hazards. They cannot smell them. They have no way of knowing the risk without being told.

The EPA’s enforcement record confirms Cagan possessed Chicago Department of Public Health lead hazard notices for multiple properties. These are official government documents — the kind a landlord receives when inspectors find something dangerous on the premises. Cagan received them, filed them, and then signed leases to new tenants without mentioning them. Any child under six living in those units during the lease periods covered in this action was exposed to that risk without their parents ever having been given the chance to make an informed decision.

The properties in question span the North Side, the South Side, and Evanston — a geographic spread that cuts across multiple Chicago neighborhoods. Lead poisoning disproportionately affects children in older urban housing stock because those are the neighborhoods where pre-1978 buildings are concentrated. The families who rent those apartments are frequently lower-income households who cannot easily absorb the cost of relocating if a hazard is discovered after the fact. Cagan’s silence foreclosed the only protection those families had: the legal right to know what they were walking into.

Economic Inequality: The Fine vs. the Windfall

Cagan Management Group agreed to pay $69,000 ($69,000 — roughly 23 months of groceries for a family of four) to the EPA, plus a parallel $30,461 ($30,461 — about six months of rent for a median Chicago apartment) to the Department of Housing and Urban Development. The combined total settlement is $99,461 ($99,461 — approximately what a Chicago public school teacher earns working two full years). The EPA’s own assessment determined this was the appropriate penalty for 57 documented federal violations spanning five years of conduct.

That math matters in a very specific way. Cagan Management Group collected rent from tenants in at least 31 units across multiple properties over the five-year violation period. Those tenants paid their rent without receiving the legally required safety information. Every month Cagan failed to disclose was a month the company collected revenue from people it had a legal obligation to protect. The fine covers roughly what a mid-tier property management company grosses in a matter of weeks. It is not a deterrent. It is a line item.

The settlement also permits Cagan to “neither admit nor deny” the substance of the allegations — the standard legal dodge that allows corporations to pay penalties without ever being forced to say, in public, that they knew about lead in their buildings and told nobody. The tenants never get a formal admission. The record shows violations; the company’s public posture remains clean. That asymmetry is a feature of the enforcement system, not a bug, and it lands hardest on renters who have no power to demand anything more.

The Cost of a Life — By the Numbers

What Now?

The Corporate Contact on Record

The Watchlist: Regulatory Bodies With Jurisdiction

• U.S. Environmental Protection Agency, Region 5 — The agency that brought this enforcement action. TSCA complaints can be filed through EPA’s enforcement reporting portal.
• U.S. Department of Housing and Urban Development (HUD) — Runs a parallel enforcement program on lead disclosure in federally connected housing. HUD’s Office of Lead Hazard Control and Healthy Homes accepts public complaints.
• Chicago Department of Public Health — Already holds lead hazard records for several Cagan properties. CDPH’s lead program investigates poisoning complaints and can compel remediation.
• Illinois Attorney General’s Office — Has authority to pursue consumer protection and tenant rights violations under state law, separate from federal EPA enforcement.
• Cook County Legal Aid for Housing and Debt — Provides free legal services to tenants facing housing issues, including habitability and disclosure failures.

What You Can Actually Do

If you are a current or former tenant of a Cagan-managed property, request your full lease file in writing, including any lead disclosure addenda. If your lease was signed between 2020 and 2025 and no lead disclosure form is attached, contact the Chicago Department of Public Health’s lead program and document the gap. Connect with tenant organizing groups in your neighborhood — organizations like the Autonomous Tenants Union in Chicago offer know-your-rights support and have experience pressuring property managers who cut corners on habitability. Community-level pressure and coordinated reporting to regulatory bodies is the mechanism that escalates a corporate fine into actual accountability. A $99,461 penalty does not change behavior. Organized, documented, persistent tenant pressure does.