If you own or manage a residential building in New York City built before 1960, the rules regarding lead-based paint have drastically changed. The mandatory August 2025 deadline for portfolio-wide XRF testing has officially passed. As of 2026, the NYC Department of Housing Preservation and Development (HPD) has shifted from education to aggressive audits, actively issuing Class C violations and massive fines to property owners who are unprepared.

At REO Lead Solutions LLC, we don’t just remove violations; we protect your real estate assets. As an EPA-Certified environmental firm based in the Bronx, we specialize in complete Local Law 31 compliance, XRF testing, and liability defense for NYC property managers.

🚨 HPD Lead Violation Codes We Clear (And How We Do It)

HPD issues different “Order Numbers” depending on whether your violation is a physical hazard or a paperwork failure. Here is the breakdown of the most common lead violations we handle, and how REO Lead Solutions gets them dismissed:

1. Physical Hazard Violations (Class C – 21 Days to Correct)

• Order #616 (Presumed Lead Paint): HPD inspectors saw peeling paint and assumed it was lead without testing it.

  • How we clear it: We perform certified paint chip or XRF testing. If it’s not lead, we submit an affidavit to get it dismissed without expensive abatement. If it is lead, we perform rapid HEPA-abatement and submit the clearance wipes.

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• Order #617 (Positive Lead Paint): HPD tested peeling paint with an X-ray machine, and it came back positive for lead.

  • How we clear it: Our EPA-certified crews encapsulate or remove the hazard, conduct independent dust wipes, and file the sworn eCertification with HPD to close the violation. (Note: If the violation is on a metal or ceramic surface, we can use the 2026 “False Positive” defense to contest the reading!)

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• Orders #621 & #622 (Friction Surfaces): HPD presumed (#621) or tested positive (#622) for lead on a deteriorated window or door friction surface.

  • How we clear it: We safely abate the friction points (or replace the components) to comply with Local Law 123 turnover rules, ensuring the unit is safe for occupancy.

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2. Audit & Record-Keeping Violations (Massive Fines)

• Orders #614 & #623 (Failure to Provide Turnover Records): HPD is auditing you and demanding 10 years of records proving you safely handled lead during tenant turnovers.

  • How we clear it: We step in to perform compliant turnover inspections and remediations, generating the legal, EPA-stamped documentation you need to satisfy HPD’s strict turnover requirements.

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• Orders #618, #619 & #620 (Failure to Provide Annual Records): You have 45 days to provide HPD with 10 years of annual tenant notices and visual investigation records.

  • How we clear it: While we cannot invent past documents, we immediately deploy our team to perform full-building XRF testing and establish a bulletproof, automated compliance and remediation system to stop the fines and satisfy the HPD audit.

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• Order #626 (Missing XRF Compliance): You failed to provide proof that your building completed the mandatory August 2025 Local Law 31 XRF testing.

  • How we clear it: We deploy our certified inspectors to your property immediately. We conduct non-destructive XRF testing across your units, generate the official compliance report, and submit the proof to HPD.

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💡 PRO TIP: The Section 11-07.1 “False Positive” Defense

Did you know you can legally contest certain HPD Lead Violations? Handheld X-ray machines often get “confused” by metal substrates, resulting in false positives. Under a new NYC regulation (Section 11-07.1), property owners can now use certified paint chip sampling to challenge positive XRF readings (like an Order #617) if the underlying surface is metal or ceramic (such as steel door frames, radiators, or tile).

 

Additionally, if you received an Order #616 Violation, you can always contest it. Before you spend thousands of dollars abating a door frame that might not even contain lead, let REO Lead Solutions perform a certified test. If we prove HPD made a mistake, we will get your violation dismissed legally and efficiently.

🛡️ Securing Lead-Free & Lead-Safe Exemptions

Why pay for annual inspections and testing every time a tenant moves out? The smartest financial move for a landlord is to secure an official HPD Exemption.

• Lead-Free Exemption: If our testing proves there is no lead paint in the unit, or if we completely abate all lead surfaces, we file for a “Lead-Free” exemption. This permanently exempts the unit from Local Law 31 turnover and annual notice requirements.

• Lead-Safe Exemption: If lead paint exists but we safely encapsulate it, we can secure a Lead-Safe exemption, drastically reducing your ongoing administrative headaches.

📍 Serving All 5 Boroughs

From pre-war co-ops in Manhattan to multi-family brick buildings in the Bronx and Brooklyn, our local teams understand the specific architectural challenges of NYC real estate. We specialize in:

• Large-Scale Portfolio Compliance

• Emergency HPD & DOHMH Violation Removal

• Pre-Purchase Lead Liability Audits

• Turnover Apartment Remediation

Don’t wait for an HPD audit to freeze your operations or trigger a tax lien. [REQUEST A PORTFOLIO COMPLIANCE AUDIT TODAY]