|The FTC Funeral Rule|
|Letter to the FTC|
|ICFA Whining (letter)|
|FCA Comments: Trade Regulation Rule on Funeral Industry Practices|
|Sudden Boycott: A letter to the FTC|
Letter to the FTC
September 24, 1997
Donald Clark, Secretary, Federal Trade Commission
Pennsylvania and 6th
Washington, DC 20580
Dear Mr. Clark:
Under the rights spelled out in FTC law and on behalf of the FAMSA Board of Directors and affiliated consumer organizations, I am requesting that the "notice and comment" review of the Funeral Rule scheduled for 1999 be moved to an earlier date. In addition, we are requesting that any such review process include public hearings; we feel that hearings will provide the best vehicle by which consumers can gain the needed changes.
The increase in funeral costs since the inception of the Rule is alarming and has continued at a rate far faster than inflation. Any delay in review will result in serious harm to consumers because of the widespread pricing abuse we have documented.
We will be seeking the following amendments and additions to the Rule:
- Elimination of any nondeclinable fee. Something that is nondeclinable by its very nature takes away consumer choice.
- We would like to see four items added to the required options on the General Price List (GPL)—private viewing without embalming, body donation to a medical school, the cost for the cremation process, and rental caskets.
- The cost of the cremation process should be included in the charge for an immediate or "direct cremation." How can one have an immediate cremation without cremation? The services and merchandise included in both immediate disposition options should be standardized for easy "shopping."
- Any mark-up on Cash Advance items should be disclosed with the actual amount to be charged. The tepid "We charge you for our services in obtaining. . . " is NOT an adequate disclosure.
- Cemeteries, monument dealers, and casket sellers should also come under the Funeral Rule. Given the mounting abuse, there is a need to protect a consumer's rights for all funeral-related purchases.
Lisa Carlson, Executive Director
While it took a while, the FTC has finally moved in the right direction. To read the FTC request for comments issued April 30, 1999, click here. And for the issues and questions that will be addressed, click here.
To their credit, many industry groups supports these changes. Only one is complaining, ICFA (letter follows).