Date: Tue, Jul 27, 1999 4:55 PM
Subject: comments on the funeral rule
to whom it may concern,
my name is kevin gray and i am founder and ceo of Direct Casket a chain of casket stores in southern california and new york. this is not my first correspondence regarding the upcoming workshop/hearings on the funeral rule but hopefully the most coherent. As the founder of the first, and probably the largest retailer of caskets since the amendment to the funeral rule in 1994, I believe I am preeminently qualified to participate in this workshop to lend a retailers point of view on the rule and its positive effect for consumers. Prior to my becoming a retailer, I owned Traditional Casket Corp. the largest distributor of all wood construction caskets in the country before Service Corp Int'l acquired most of my accounts and forced me to sell out.
From our inception, I hypothesized that it would be a difficult road just providing caskets to consumers who would then have to face an "angered" funeral director. This hypothesis has proven to be true based upon the feedback we receive from various customers. Although funeral directors are obliged by law, many choose to either circumvent it or ignore it entirely. I have stacks of surveys returned from customers citing egregious acts imposed upon them by funeral directors in order to either dissuade them from using our service or at the very least, make them feel extremely uncomfortable.
Unfortunately, many of these documented complaints appear to have gone unheeded by the Federal Trade Commission.
Since our inception, we have sold over 7000 caskets. We calculate an average savings to the consumer of at least $1000 per casket. Additionally, we believe we save consumers an average of $1000 per funeral on the service charge by either referring them to a lower cost provider or giving empowering them to make informed decisions when arranging the funeral themselves.
Lastly, we cna only guess at the money consumers have saved by ultimately purchasing their casket from the funeral home at a "matched" price where the funeral home agreed to match our significantly lowwer prices only to salvage something and hopefully put us out of business in the process If you total these estimates, we calculate we have saved consumers almost $15 million dollars since our inception.
It would be a crime to enact legislation or amend the rule in any way that either puts us under the thumb of the funeral industry (read funeral homes) or precludes us from competing fairly with funeral homes by allowing them to start charging a handling fee. In fact, some are doing just that by inflating their existing service charges to those who purchase a casket elsewhere but offering a discount to only those who buy the casket from them. Perhaps this loathsome practice of "sham discounting" can be explored at these hearings.
I hope I am given the opportunity to participate. As a former owner of a rather large distributorship of caskets to funeral homes, I have been on all ends of this business and would be glad to give a point of view that at the very least, would be most enlightening.
Please let me know if I will be asked to participate.