To: HQ.DCMAIL3(FUNERAL)

Date: Fri, Jun 18, 1999 11:34 AM

Subject: "16 CFR, Part 453"

As a licensed funeral director, I wish to express my views on the FTC funeral rules.

First, allow me to state, that in general, I have been quite pleased with the 16-item rules---with a few exceptions.

In my opinion, it appears that in addition to Basic Services of funeral director and staff/and a share of overhead, the other "non-declinable" item should be imposed for "Transfer of remains from place of death to the funeral home."

Perhaps state regulations differ from state-to-state regarding removal of remains. However, it appears that most states have a ruling that removals must be handled by licensed funeral professionals.

Therefore, when I explain the rules to client families, they can clearly see that under FTC rules--- they have the right to pick and choose ONLY the goods and services that they want. But regardless of their choices, the fact remains that a Licensed funeral director Must be given authorization by the next of kin or responsible party to transfer the remains from the place of death to the funeral home.

Nevertheless, I firmly believe that rules must, without question, be expanded to include the reguation of cemeteries and "third party merchandise suppliers."

I honestly conclude that the 16-items FTC ruling has, without a doubt, made me look better in the eyes of my clients.

Cemeterians on the other hand, are the ones who are taking full advantage of consumers. In many instances, I could provide proof of cemeteries that have policies that are in restraint of trade. Most independent monument dealers are well aware of this.

Furthermore, it is rather obvious that if consumers have desires---other than what the cemetery has in mind---that the consumer will be severely penalized for choosing to select something that is "against policy."

In a nutshell, if one of my clients wishes to provide their own casket and memorial items and transport the remains to the cemetery in their own vehicle---by federal law, I must allow them to do so. And I honestly have no objection to any of that. In fact, in some instances, there are many things that I encourage---simply to help some clients in any possible way. I realize that a satisfied client will always know who to contact in their time of need.

But at many cemeteries, consumers are forced with restrictions that leave many families unsatisfied to the extent that they realize that they were taken full advantage of.

Please consider the valid recomendations of the National Funeral Directors Association regarding these issues. This may result in our government helping Americans get a fair-shake on a part of life that is inevitable .

Thank You.

Fd1292