Collier Casket Co.
720 Hwy 183 South
Suite 103
Austin, Texas 78741

August 7, 1999

Secretary, Federal Trade Commission
Room H-159
600 Pennsylvania Ave, NW
Washington, DC 20580

Subject: 16 CFR Part 453, Comments Concerning Trade Regulation Rule on Funeral Industry Practices.

Dear Secretary,

The Funeral Rule is critically important to families that are in need of a casket. Most families still have no idea there is a law that protects their right to select a casket from a source other than the funeral home. There is still a fear that if they purchase a casket from a source other than the funeral home, it will not be accepted or there will be an additional cost charged to them. It is this assurance that the federal government is behind them that gives many of the families the courage to make a selection. The value of the Funeral Rule to families, especially families of limited means, is immense.

Families Speak Out

I have recently mailed a survey to families that have allowed our company to supply their casket. The voices of the families were unanimous on two survey questions.

1. Do not eliminate the Funeral Rule and thus remove our only protection from a casket-handling fee. To allow the funeral industry to add a handling or inspection fee, especially an unlimited fee, could negate any savings now available to a family that supplies there own fair priced casket.

2. Do not allow the funeral homes to establish unrealistic (fictitious) prices and only allow a price reduction if the casket is purchased from the funeral home. There are so many games and tricks being played on families to eliminate their freedom to make cost savings decisions. Whither the game falls under the name of "Sham Discounting", tying, or bundling its only intent is to frustrated the intent of the Funeral Rule. Families desperately need your assistance to end this abuse.

Economic Impact on the Families

According to the survey figures supplied by the families, the estimated savings compared to the prices they encountered at the funeral homes averaged over $1500. Considering our metal caskets range in price from a low of $395 to a high of only $1495, an average savings of over $1500 represents a substantial percentage. You would have to be in my office while a family is using the phone trying to contact enough relatives to cover the cost of an unexpected funeral, to truly realize how important that savings on a casket can be. Anything that stands in the way of their right to purchase a fair priced casket should be eliminated.

Six copies of the returned survey forms are being forwarded under separate cover. The survey forms will verify the numbers stated in this letter. Several of the families have added written comments for your consideration.

Sincerely,

Bill Collier
Collier Casket Co.