EPA conducted an on-site random neutral scheme inspection at Respondent's office in Rome, NY to evaluate their compliance with the Disclosure Rule. Respondent is a lessor of approximately 190 units of target housing at multiple locations in/near Rome, NY and was not always performing Disclosure. Subsequent testing showed that some of the structures contained Lead-Based Paint, while others were lead-free. After the EPA inspection the Respondent performed Disclosure to come into compliance, tested all properties for the presence of lead, and removed building components that were found to contain lead based paint.