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An independent public accountant performed audits of the Willow Run (FHA no. 092-44100) and Willow Run II (FHA no. 092-35650) multifamily properties for the years 2005, 2006, 2007, and 2008 under the name of The Blackwing Group, LLC.  According to the Minnesota Board of Accountancy, neither the independent public accountant nor The Blackwing Group, LLC, had ever been licensed to perform public accounting engagements in the State of Minnesota.

The same independent public accountant also performed audits of the Willow Run and Willow Run II properties for the years 2009, 2010, 2011, and 2012 under the name of an unrelated firm and falsely claimed to be working for a licensed certified public accountant firm that had never employed her.

In October 2017, HUD’s Departmental Enforcement Center notified the independent public accountant of her debarment from future participation in procurement and nonprocurement transactions, as a participant or principal, with HUD and throughout the Executive Branch of the Federal Government, for an indefinite period.


Key Details
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Funds Put to Better Use
Funds Put to Better Use

Recommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.

Questioned Costs
Questioned Costs

Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.


Sensitive information refers to information that could have a damaging import if released to the public and, therefore, must be restricted from public disclosure.


We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.

General Counsel

  •   2018-CF-1802-001-A

    Closed on March 23, 2018

    Ensure that HUD completes the debarment process and appropriately notifies the independent public accountant of the debarment decision.