Payne Revocable Trust leases Tudor East Apartments, located in Anchorage, Alaska. From 2007 to 2009, Respondent owned and leased the Tudor East Apartments. The apartments were built before 1978. Therefore, during calendar years 2007-2009, Respondent was a lessor of target housing as defined in 40 C.F.R. § 745.107. During this time period, Respondent leased 38 units a total of 81 times. While it appears that Respondent failed to comply with the Disclosure Rule all 81 times, the EPA is proposing to assess penalties only for the violations associated with the leases for units 3, 7, 10, and 12. Respondent leased these four apartments a total of 12 times during calendar years 2007-2009. Payne Revocable Trust will pay $2,000 penalty.