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Landlord lead paint disclosure for rentals: leases, renewals, tenants

Landlords and property managers of pre-1978 rentals often ask when lead disclosure is due and what counts as a new lease. This page sums up what the EPA and HUD interpretive guidance says for rental situations.

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Answers are written by a language model solely from this base's documents, with numbered sources. They can be wrong and aren't legal, medical or financial advice: check the sources before any important decision.

Month-to-month and short-term leases

Leases of 100 days or less are excluded, but only where no renewal or extension can occur. If both parties want to extend an exempt short-term lease beyond 100 days, all disclosure requirements must be met before the extension.

An open-ended month-to-month arrangement, written or unwritten, is covered from the initial agreement, since the term is not limited to 100 days or less.

Renewals and changes to the lease

When a lease switches to open-ended month-to-month after an initial period, EPA and HUD treat renewal as occurring when the tenant becomes obligated to that change. A rental rate adjustment is also a significant change constituting renewal.

After such a change, an initial disclosure is required if none was made before, or any new information obtained since the first disclosure must be disclosed. An owner may send disclosure forms to all existing tenants at once, but new information obtained before a renewal must still be disclosed before the tenant signs.

Records and reports for tenants

Lessors must provide available records and reports on lead-based paint. For inspection and risk assessment reports, a summary is allowed if it is prepared by a certified paint inspector or risk assessor.

If excerpts or summaries are given instead of full copies, tenants must be able to review the complete documents in a central location on the premises where feasible, and receive copies on request at no cost.

In large multifamily properties, inspectors often examine a representative sample of units and apply the findings to the whole building. EPA and HUD consider reports from such building-wide evaluations directly relevant to prospective tenants of individual units, even units not specifically examined.

Frequently asked questions

Must a landlord test the unit before renting it?

No. Renters can ask for a paint inspection by a certified inspector before signing a lease, but the Disclosure Rule does not require landlords or property managers to arrange one.

Who discloses in a co-op or condo building?

If the corporation or association is not the seller or lessor and not the owners' legal representative, it has no disclosure duty. The individual seller or lessor must then obtain any information it holds and include it in the disclosure.

Are timeshares covered?

Leases of timeshares for 100 days or less per visit are excluded. The sale of a timeshare interest of less than 100 days per visit is also excluded when the owner does not obtain or retain a deeded interest to a specific unit.

Is an original signature required on the form?

Not under the federal rule: a signature may be reproduced, for example by photocopy, fax, autopen or rubber stamp, without relieving the signer of responsibility. Sellers and lessors should still check whether state law requires original signatures.

For developers and agents

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MCP for your agents

This base's MCP server URL (tools ask_base and search_base):

MCP URL
https://kopik.io/api/mcp?base=us-lead-paint-disclosure-renovation-rules
Claude Code, Cursor and other clients
Claude Code
claude mcp add --transport http kopik-us-lead-paint-disclosure-renovation-rules "https://kopik.io/api/mcp?base=us-lead-paint-disclosure-renovation-rules" --header "Authorization: Bearer kpk_…"
JSON config (mcpServers)
{
  "mcpServers": {
    "kopik-us-lead-paint-disclosure-renovation-rules": {
      "url": "https://kopik.io/api/mcp?base=us-lead-paint-disclosure-renovation-rules",
      "headers": {
        "Authorization": "Bearer kpk_…"
      }
    }
  }
}

REST API for your apps

mode is "answer" (written answer + sources) or "passages" (raw passages only). Add an optional maxPriceCents to cap the price: if the base costs more, the call is refused and nothing is charged.

curl
curl -X POST https://kopik.io/api/v1/bases/us-lead-paint-disclosure-renovation-rules/query \
  -H "Authorization: Bearer kpk_…" \
  -H "Content-Type: application/json" \
  -d '{"question": "Your question here", "mode": "answer"}'

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