Crown Realty & Management Corporation

Lead Paint Policy and Procedures

Our policy is we will not mange houses built before 1978 unless they have been tested for the presence of lead and found lead free.

I. Regarding New Owner Sign-Ups

Do your due diligence!

●Get owner to declare the date the property was built and have them sign a lead paint disclosure.

●Look at tax records and make sure the build date is 1978 or later. If tax records list a rehab date later than 1978, treat it like a pre-1978 built house.

●When in doubt, pull deed records and see if you can find a deed dated before 1978.

●If the year it was built is not clear, see your broker.

If you find the house was built before 1978, here are the rules for taking on management:

1.Provide Crown with a properly executed lead paint test completed after April 2010 with details of the testing process. We will examine it and check out the tester. If the broker approves it we will manage the property. Broker approval is required.

2.Have the property tested before we begin marketing it. Get the results of the test and we’ll evaluate. Keep the report on the P drive and attach to APPfolio. Broker approval is required.

3.After educating the owner on the issues, we’ll do Tenant Placement. (see notes below)

When an owner claims “I just totally renovated it so there is no lead paint” suggesting we should turn our brains off and manage the property we probably won’t.

What they are suggesting is “because there is no painted surface from the old house there’s no danger. There might still be. Probably they didn’t cover all the concrete and dispose of the sheetrock dust as they did their work. If the house had lead paint it will be all over the framing, slab, around the HVAC systems, etc. and they want us to believe it’s all gone. If they will get it tested we’ll manage it. Otherwise they’ll have to find another manager. This is too big an issue to take risks. The consequences are just too great.

II. Regarding Tenant Placement

If a property was built before 1978 we’ll notify the owner of the issues, refuse to do any repairs or rent ready work on the property, and lease it for them with the proper disclosures.

III. Regarding houses we already manage note the following:

Lead Paint issues will be handled by the property manager and Broker; not the assistant property manager. Because we already manage houses built before 1978 we need to examine them carefully to determine whether or not we will continue to mange them.

Steps to the process:

1.Immediately complete an audit of our entire inventory and identify every property built before 1978.

2.On the front of each file put a large white mail label with big letters Pre 1978 with a felt tip identifying it as a pre-1978 house.

3.Log it in management software.

4.Create a master list with notes as to renewal dates, age and status of occupants and divide by zone. Each zone is responsible for managing their list. On the master, managers are to make notes as things unfold and update the issues. Managers must report to Broker monthly regarding the status of their list. We are also keeping the list on a white board in the office to keep it in our face.

Let’s deal aggressively with the ones we are currently managing in this priority:

1.Scheduled Move-In’s
If you identify a pre 1978 house on a move-in log stop the move in and see your broker. We will not do the move in until it has been tested. See your Broker.

2.On the market for lease
Identify any currently available for lease. If you find one see the broker and let’s contact the owner to get approval to test for lead. We will not take an application until we have a cleared lead paint report.

3.Notices to vacate
Identify the properties on notice to move. Notify the owner we will only continue to manage the property if the property has been tested and is found lead free. Send them to our lead paint web page for education on the issue and get them to test or terminate the property. If the owner resists, bring to broker.

4.Skips and evictions

Before we re-rent the house must be tested. Notify the owner during the eviction process and address the issue head on. Send them to the lead paint home page. If the owner resists and refuses to have the property tested, bring it to your broker immediately.

5.OccupiedHouses

a.If no maintenance has been called in contact the owner immediately and alert him as to the issue and send them link to our lead paint web page. Notifying them in advance will make it easier when large repairs are needed and testing is required. See the renewal policy below. When the property comes up for renewal we’ll do the testing.

b.When maintenance is called in

Any repair request requiring less than 6 feet of painted surface to be disturbed can be done without broker involvement. Get help if you have any question as we don’t want to mess this up. Be careful ordering work on these houses.

If it appears that there is 6+ft to be disturbed, STOP and see your Broker. The property manager will own this issue but under the careful supervision of your broker.

c.Emergencies

We can do emergency repairs without testing. Any emergencies on untested houses must come to broker after the emergency is over but before further work is done.

d.Up for renewal

120 days out contact the owner, explain the issue, and send him a link to our web page. The house must be tested before the 60 day auto-renewal date. If the owner resists, bring it to the Broker.
If you get close to the 60 day auto-renewal see your Broker. Send the non-renewal letter to tenant until the testing is done so it doesn’t auto-renew.

If there is lead in any amount bring it to the Broker. If no lead is found renew the lease and keep the property. Modify your master list of pre 1978 properties. Don't renew without a copy of the clearances letter in hand. Put it on the P drive and attach to management software. Show the broker
The process:

We have identified a lead paint tester and intend to use him. Do not change who we use without broker involvement. Jeremy ______is our broker-approved tester at ______

If the owner insists on using someone else, SEE YOUR BROKER. There are lots of newbees in the lead paint testing business that do not do repairs as a business and don’t have General Liability insurance or workman’s compensation. We will resist hackers doing testing on properties we manage.

Never Order Testing on a Property without Broker Approval! Never order testing! NEVER! Only the owner should order testing. In some cases the Broker will order it to protect the company. We don’t want the lead report in our name. When testing is approved by the owner we’ll let the owner actually order it. Put the owner in touch with the tester and get an email that we are to pay for it from owner’s funds if there are any.

When the report is complete get a copy of it for our records. Hearing from the owner “its lead free” is not safe. We need the report. Review it carefully before you add it to the P drive and link it to Appfolio. Be sure to keep the master report, Appfolio and the board current.

IV. Regarding Houses with Home Warranties

This is a particularly disturbing area because so many warranty companies aren’t up-to-speed with the problem and they hire local contractors that aren’t either. Since we are the ones that will be sued if the contractors do this wrong, we need to pay close attention to what is going on in the property while we have a tenant there. If the repair is obviously small and will probably not disturb a 6 foot square area of painted surface, go ahead and let the warrantee company in. If the repair could be a problem we will stop the contractor from entering the property until we are sure of the job size. We have to manage this not the owner or the warranty company. The liability of this issue is so severe that it will be closely managed personally by your broker. I will not be delegating this to anyone. Within a year all our houses will have been lead paint tested so this is not a long term challenge.

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