Respondent manages approximately 367 rental units for multiple owner groups. Findings from a neutral scheme inspection and Information Request Letter in 2008 indicated the Respondent did not always perform lead paint disclosure. After receiving EPA's Administrative Complaint with a proposed penalty, the Respondent provided copies of signed Disclosure forms, eliminating many of the Counts. Respondent provided further documentation after an informal settlement conference was held at 290 Broadway on 12/1/2010, earning additional penalty reductions.