The Non-Financial Ledger: What a Lease Signed in Silence Actually Costs

Picture it: you find a place, sign a lease, and start moving your life in. Maybe you have kids. Maybe you have a toddler who puts their fingers on walls and then in their mouth, the way every toddler does. Nobody handed you a pamphlet. Nobody told you the house was built before 1978. Nobody said the words “lead paint.” You had no idea you were supposed to get any of that information, because why would you know? That’s the landlord’s job. That’s the law.

Lead poisoning is not dramatic. It does not announce itself. There is no fever, no rash you can point to. It is slow and invisible and accumulates in bones and blood over months. In children under six, it attacks the developing brain directly. It lowers IQ. It shortens attention spans. It causes behavioral problems that follow a child into school, into adolescence, into adulthood. Pediatricians call it a silent epidemic because the damage is done long before anyone thinks to test for it.

The federal lead paint disclosure rule exists precisely because of this silence. Congress passed it in 1992. The EPA and HUD finalized the regulations in 1996. The rule says: if you are renting a home built before 1978, you must tell the tenant what you know about lead paint in that home, give them the government’s own pamphlet explaining the risks, and put it all in writing before they sign anything. The purpose of that pamphlet is to give renters the information they need to make a choice, or at minimum, to know what to look for, what symptoms to watch, and when to call a doctor.

R.A.L. Property Management skipped all of it. Not part of it. All of it. The company signed the lease on February 14, 2024 and, according to the EPA’s enforcement record, performed “no other lead-based paint disclosure activities” before the tenant was legally bound to that home. That tenant, whoever they are, walked into a pre-1978 house with no warning, no pamphlet, and no written acknowledgment that any of this even existed. The EPA does not name the tenant in its enforcement documents. Their story, their health, and whatever happened inside that house at 1032 West Pacific Street in Springfield, Missouri, is not in the file.

What is in the file is a settlement. R.A.L. pays $16,708, signs the paperwork, and walks away with a neither-admits-nor-denies clause protecting it from full accountability. The tenant gets nothing from this proceeding. The fine goes to the U.S. Treasury. The harm, if any was done, is not measured in dollars anywhere in this document.

That sentence, lifted directly from the EPA’s findings, is the entire story in one clause. A family moved into a house that may contain lead paint, and the company that owns that house did not hand them a single page of information. The law required it. The company chose not to do it. That choice, multiplied across every landlord who makes the same calculation, is why lead poisoning in rental housing remains a documented public health crisis three decades after Congress declared it one.

Legal Receipts: What the Federal Documents Actually Say

These are not paraphrases. The following quotes are pulled verbatim from EPA Docket No. TSCA-07-2025-0046, the Consent Agreement and Final Order signed by EPA Region 7 and R.A.L. Property Management, LLC, filed April 1-2, 2025.

“Respondent entered into a contract to lease the target housing unit located at 1032 West Pacific Street in Springfield, Missouri 65803 on or about February 14, 2024.”

“Respondent failed to provide the lessee of 1032 West Pacific Street with an EPA-approved lead hazard information pamphlet or to perform any other lead-based paint disclosure activities before lessee were obligated under contract to lease the target housing unit.”

“Respondent: (a) admits the jurisdictional allegations set forth herein; (b) neither admits nor denies the specific factual allegations stated herein; (c) consents to the assessment of a civil penalty, as stated herein.”

“This CAFO constitutes a ‘prior such violation’ as that term is used in EPA’s Interim Final Consolidated Enforcement Response and Penalty Policy… to determine Respondent’s ‘history of prior such violations’ under Section 16(a)(2)(B) of TSCA.”

“Full payment of the penalty proposed in this Consent Agreement shall not in any case affect the right of the Agency or the United States to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law.”

What You Were Told vs. What Was Hidden

The gap between a landlord’s legal obligations and what R.A.L. actually delivered to this tenant is total. Every column below is backed by the EPA enforcement record.

Societal Impact Mapping

Public Health

Lead paint in pre-1978 rental housing is the leading preventable cause of childhood lead poisoning in the United States. The federal disclosure system is the first and most basic line of defense.

• Lead exposure at any level causes neurological damage in children under six. The CDC states there is no safe blood lead level. R.A.L.’s tenant moved into a pre-1978 home with zero warning that lead paint might be present, removing their ability to protect children or other vulnerable people in the household.
• Lead paint hazards are generated most dangerously through deteriorating paint, dust from renovation or normal wear, and painted surfaces near windows and doors where friction occurs. Without the EPA pamphlet, a tenant has no baseline knowledge of these specific risk pathways inside their own home.
• Low-income renters, who are disproportionately tenants of older pre-1978 housing stock, are the population most affected by landlord non-compliance with disclosure rules. They are also the group least likely to independently know their disclosure rights or access legal resources when those rights are violated.
• Blood lead testing for children is the only way to confirm exposure after the fact. A tenant who was never told they might live in a lead paint environment has no reason to request that test from their pediatrician. Undisclosed violations like this one systematically delay diagnosis.

Economic Inequality

The financial math of this case reveals a system that prices safety violations as an acceptable cost of doing business rather than a deterrent.

• The maximum inflation-adjusted penalty for this type of violation was $49,772 per violation under the Federal Civil Penalties Inflation Adjustment Act as of January 8, 2025. R.A.L. paid $16,708, which is 33.6 percent of the legal maximum. The tenant received zero financial remedy from this enforcement action.
• The penalty is also classified as non-deductible for federal, state, and local taxes under the consent agreement. However, landlords can and do factor routine compliance failures into operating costs when the fine is this small relative to rental income streams across a property portfolio.
• Renters in Springfield, Missouri, like renters in most mid-sized American cities, have limited options to independently verify the lead paint history of a rental unit before signing. The entire disclosure system depends on landlord compliance. When landlords skip it, the financial burden of any resulting health harm falls entirely on the tenant through medical costs, lost wages, and reduced earning capacity caused by childhood neurotoxicity.
• R.A.L.’s consent agreement explicitly states the settlement does not affect the tenant’s right to pursue separate civil remedies. However, individual tenant lawsuits against landlords require legal representation, discovery, and resources that most low-income renters do not have access to.

The Cost of a Life: Penalty in Context

What Now: Who to Watch and What to Do

R.A.L. Property Management, LLC is now a documented federal violator of lead paint disclosure law. These are the parties, regulators, and actions that matter going forward.

The Parties on Record

• R.A.L. Property Management, LLC: The respondent. A limited liability company registered in Missouri. Contact on record: Attorney Ellen Goldman, EGoldman@sb-kc.com, 2323 Grand Boulevard, Suite 1000, Kansas City, MO 64108.
• David Cozad: Director, Enforcement and Compliance Assurance Division, EPA Region 7. Signed the consent agreement for the EPA on March 31, 2025.
• Jennifer Trotter: Attorney, Office of Regional Counsel, EPA Region 7. Prosecuting attorney on this case. Contact: trotter.jennifer@epa.gov.
• Karina Borromeo: Regional Judicial Officer, EPA Region 7. Signed the Final Order on April 1, 2025, ratifying the settlement.

Regulatory Watchlist

• EPA Region 7: The primary enforcement body for this case, covering Missouri, Iowa, Kansas, and Nebraska. R.A.L. is now in their violation database. Any future R.A.L. lead paint violation triggers the “prior such violation” clause from this settlement.
• HUD (Department of Housing and Urban Development): HUD jointly administers the lead paint disclosure rules with the EPA under the Residential Lead-Based Paint Hazard Reduction Act of 1992. HUD also administers the healthy homes program and can pursue separate enforcement on federally assisted housing.
• Missouri Attorney General’s Office: State-level consumer protection enforcement can pursue landlord violations independently of federal EPA action, including deceptive trade practices claims for failure to disclose known hazards.
• Springfield-Greene County Health Department: The local public health authority for the address at 1032 West Pacific Street, Springfield, MO. Residents can request lead hazard inspections and report suspected violations here.
• CDC’s Childhood Lead Poisoning Prevention Program: Tracks blood lead level data at the state and county level. If you or someone in your household was or is a tenant at 1032 West Pacific Street and was never given lead paint disclosures, a blood lead test through your primary care provider or local health department is the first step.

What You Can Do

• Know your rights as a renter in pre-1978 housing. Every landlord in the country is legally required to give you the EPA’s “Protect Your Family from Lead in Your Home” pamphlet before you sign a lease. If you did not receive it, that is a federal violation you can report to your EPA regional office at epa.gov/lead.
• Report non-compliant landlords directly to EPA Region 7 if you live in Missouri, Iowa, Kansas, or Nebraska. The enforcement contact for this region is the Enforcement and Compliance Assurance Division, 11201 Renner Boulevard, Lenexa, Kansas 66219.
• Connect with local tenant organizing networks in Springfield, MO. Organizations like legal aid societies and tenant rights groups can help you demand disclosure records, request inspections, and understand your options for civil remedies that the EPA settlement did not provide.
• If you are a parent in a pre-1978 rental home and no one handed you a lead paint pamphlet at signing, request a blood lead level test for any child under six from your pediatrician. The CDC’s reference value for elevated blood lead is 3.5 micrograms per deciliter. Early detection is the only intervention that can limit long-term neurological damage.
• Pressure local Springfield city council members to adopt proactive lead paint inspection requirements for rental housing, rather than relying solely on federal enforcement action after violations have already occurred.