In response to an August 28 letter from Churchill CEO Bill Carstanjen sent to the Federal Trade Commission, the CEO of the Horseracing Integrity and Safety Authority, Lisa Lazarus, has issued a letter of her own to the FTC countering several of Carstanjen's points.Lazarus opens with the Angel Quiroz betting scandal.“Mr. Carstanjen opens his letter by asserting that the industry is still awaiting meaningful answers regarding the wagering activity associated with the Fair Hill Five. To the extent he suggests that HISA bears responsibility for providing answers regarding wagering activity, that assertion conveniently overlooks the fact that HISA's congressional mandate does not include the regulation of betting markets and HISA, therefore, has zero authority over wagering activity. HISA will continue to publicly disclose any additional findings related to the conduct of the `Fair Hill Five' that fall within its jurisdiction under the Racetrack Safety Program or Anti-Doping and Medication Control (ADMC) Program, as information becomes available, consistent with its longstanding commitment to transparency.”After the apparent betting coup, HISA conducted out-of-competition testing on Quiroz's horses, and issued him a provisional suspension after three of them tested positive for Albuterol, a bronchodilator. Quiroz is unable to train while the case is adjudicated. He was also charged with compromising the welfare of covered horses for a competitive or commercial gain.“The apparent criticism of HISA on this topic is particularly interesting given CDI's own position within the industry,” writes Lazarus. “In his letter, Mr. Carstanjen describes CDI's ownership of an advance deposit wagering platform and the company's direct and substantial interest' in wagering. It follows, then, that CDI would be uniquely positioned and should be motivated to identify suspicious betting patterns and take action to protect its customers and the industry at large. But, when a horse linked to the `Fair Hill Five' was scheduled to race at a CDI-owned racetrack the very next day, CDI took no action to prevent the horse from racing despite having been made aware of the issue and presented with an opportunity to act. It was HISA that took the appropriate steps to protect the horse and other racing participants.”HISA used its authority to place Threedots Andadash on the vet's list when he was entered to race at Presque Isle Downs, a Churchill-owned track, after the stewards declined to do so.Carstanjen's letter had criticized the timing of the release of the medication positives.“Once again,” Lazarus writes, “this appears to be an effort to generate misplaced concern rather than to engage with the relevant facts. In this particular case, the timing of the alleged violation followed the very process that has been in place for approximately the last two years. Public notification of an alleged violation is not made until the B sample is waived or the result is returned confirming the A Sample. If the B sample is waived, public disclosure is made when the notice of violation is served to the Covered Person. If it is not waived, the public disclosure is made following the return of the B Sample. The Horseracing Integrity & Welfare Unit followed HISA's public disclosure procedures to the letter and there was no deviation whatsoever from its standard protocol.”Carstanjen's letter also addressed the Marshall Gramm scandal, wherein HISA identified Gramm as the person who had taken others' equine medical records to create enhanced past performances.Lazarus points out that TwinSpires.com, Churchill's wagering platform, was also the victim of a cyber attack in 2012, a common occurence for many companies.“In HISA's case,” the letter says, “within weeks of discovering the issue, HISA triggered its cyber insurance policy and retained an independent third-party cybersecurity expert to conduct a forensic investigation, identified Dr. Gramm as the individual responsible, publicly disclosed Dr. Gramm and the vulnerability that was exploited, notified law enforcement, initiated an internal enforcement action against Dr. Gramm and updated our systems to address the exploited vulnerability. In addition, HISA has accelerated the timeline for the independent IT audit required under the Commission's Oversight Rule and is in the process of engaging a third-party auditor to conduct a comprehensive review of its systems, including the vulnerability at issue. The results of that audit will be provided to the Commission, and we look forward to working with the Commission to keep our stakeholders informed on these issues and further strengthen our systems.”Finally, Lazarus points out the amount of public engagement which HISA has undertaken since the incident.“HISA has embraced an unprecedented degree of transparency and communication regarding the Gramm incident, engaging directly with stakeholders through press conferences, podcast interviews, public statements and responses to numerous media inquiries,” she writes. “Rather than withholding information pending the conclusion of lengthy investigations, HISA has recognized the importance of earning and maintaining the trust of industry stakeholders and has consistently sought to provide timely, accurate updates and candid explanations regarding the incident.” The post HISA CEO Lisa Lazarus Issues Response to Churchill Letter to the FTC appeared first on TDN | Thoroughbred Daily News | Horse Racing News, Results and Video | Thoroughbred Breeding and Auctions.