| July 28, 1999
Secretary, Federal Trade Commission Dear Commissioners: Schrader Funeral Home, a family-owned firm in the St. Louis, Missouri metropolitan area, appreciates this opportunity to express our view of the Funeral Rule and its up-coming review. We feel that it is imperative that the scope of the Funeral Rule be broadened to cover ALL providers of funeral goods OR services. Since the implementation of the funeral rule in 1984, and even since its 1994 amendment, there have been marked changes in how funeral merchandise can be purchased. Today, you can sit at your home computer and purchase burial and cremation caskets, urns, and a myriad of other funeral-related products. In the St. Louis market there are five cemeteries selling caskets, even more selling outer burial containers, and one casket store. The Internet situation and the local market situation did not previously exist and must be addressed. The vendors of these funeral goods are not currently required to conform to the provisions of the Funeral Rule because they do not offer funeral goods AND services. We believe the intent of the Funeral Rule is to protect the consumer. While the consumer has been afforded protection in the form of written price statements (General, Casket & Outer Burial Container Price Lists) offered by funeral homes, consumers who seek information or purchase goods from other sources - such as casket stores, cemeteries and Internet sellers - are not afforded the same protection under the rule. Our firm believes that the inclusion of all providers of funeral goods or services will best serve the buying public. Sincerely, Dennis L. Goethe, CFSP, MBIE |