35600 Main Street
New Baltimore, Michigan 48047

July 8, 1999

VIA E-mail

Federal Trade Commission
Washington, D.C.

Re: Funeral Rule Public Comment

I wish to express two thoughts for your consideration when deciding what course the funeral rule will follow in the future:

1. I would like to see the rule expanded to cover all providers of funeral merchandise. This would include cemeteries and other third party providers. Everyone should be playing by the same rules.

2. I believe the consumer is not being treated with fairness and respect when the rule requires funeral directors to present the General Price List at the beginning of any discussion of funeral details. I think the intent of this requirement is good, but the timing of presentation is wrong. This presentation could certainly be delayed until the funeral director has had an opportunity to ascertain what service options the family will need, dependent upon the type of service they desire. At that point the funeral director could present the GPL and describe the specific applicable charges with the family. An explanation could be made to indicate to the family that their selections can be changed if they think certain fees are excessive or are not required.

I think many families are insulted by having the GPL handed to them at the beginning of the arrangement conference, despite what type of preliminary dialog has taken place. Families are in a confused state and the last thing they want to talk about initially are charges.

Thank you for receiving these comments.

Sincerely,

David A. Kesner, Director
Gendernalik Funeral Home, Inc.
and
member of the Board of Directors
Michigan Funeral Directors Association

CC: FTC.SMTP("MMaire@mfda.org")