On December 30, 2011, EPA Region III filed an administrative Complaint and Notice of Opportunity for Hearing against Crespo Realty, Inc. of Flushing, New York alleging 25 violations of EPAÂs regulations implementing the Residential Lead-Based Paint Hazard Reduction Act (the ÂDisclosure RuleÂ). The Complaint alleges that Crespo Realty, Inc., owner and lessor of four (4) target housing units in Reading, Pennsylvania, failed to include, as part of five leases for the housing units, required information concerning knowledge of lead based paint and/or lead based paint hazards; available records or report pertaining to lead based paint or lead based paint hazards; receipt of information by lessee; and required signatures and dates. The Region did not request the assessment of a specific penalty for such violations in the Complaint but will do so in its prehearing information exchange to be submitted at a later date, as permitted by the Consolidated Rules of Practice, 40 C.F.R. Section 22.14(a)(4)(ii) and .19(a)(4). The Complaint notes that the statutory maximum penalty for violations of the Disclosure Rule alleged therein.