From: "JAMES BROUSSARD JR" <BROUMOR@worldnet.att.net>
To: HQ.DCMAIL3(FUNERAL)
Date: Wed, Jul 28, 1999 3:57 PM
Subject: proposed funeral rule changes

I am a fourth generation Funeral Director with my families business in Beaumont, Texas. Our family has been an active supporter of the Funeral Rule. My Father James Broussard Sr.. testified on behalf of the Texas Funeral Association a number of years ago in favor of nation wide standards for consumers.

Here are my families thoughts on these specific proposed changes.

Funeral Providers: all interests that sell merchandise that the general public associates with death care should be included without exception in the Funeral Rule.

Casket Handling Fees: The issue brought to attention is not necessarily the casket handling fee but the use of packaging of services. We would ask the commission to do away with packaging all together. The spirit of the rule is to provide consumers with individual pricing only for the goods and services selected. We feel packaging encourages funeral providers to promote the package price and not give consumer all their options.

Non-declinable Fees: This charge is one of the least questioned charges on our GPL. It is very defendable and is effective in demonstrating the different services funeral providers offers.

Requests for Comment.

1.Yes, there is a continuing need for the Funeral Rule.

a. It has defined from the onset charges selected and dollars spent by consumer families at time of funeral planning.
 
b. there may have been some cost associated with compliance. Its positive effects outweigh the negative.

2. we suggest that all providers of death care services and merchandise be included in the rule.

a.again the rule should have no significant cost effect to consumers.

3. none other than printing.

a. the rule has forced funeral providers to be better managers of their companies. it has been healthy for the industry.

Items 4 through 9 have all been answered previously.

Items 10 through 29 not view as significant questions.

Government has not realized the vast majority of consumers refuse to shop for prices. The Big Conglomerates know this and capitalize on it. That is why there are no name changes associated with the sale of company's.

30. yes there are many misrepresentations associated with pre need sales of funerals. The large companies are educating sales people in their ways of marketing. These people only know what they have been taught. There are gross misrepresentations occurring daily.

Thank you for allowing me to vent my frustration with Publicly held funeral companies. It will be interesting to see if what we have allowed to happen in our industry will eventually destroy it.

Jim Broussard Jr..
Vice President
Broussard's Mortuary
P.O.Box 5507
Beaumont, Texas 77726
broumor@att.net