To: "Secretary, FTC" <funeral@ftc.gov>

Date: Tue, Jun 22, 1999 11:30 PM

Subject: Funeral Rule Revisions

Dear Secretary,

I write to you in my capacity a a licensed funeral director and funeral home owner in the State of Pennsylvania, regarding the FTC Funeral Rule.

I believe that the Funeral Rule, in particular the General Price List requirement, has been helpful to consumers in order that they may shop funeral prices and make various comparisons among different funeral homes.

Additionally, I strongly believe that the rule has increased competition among funeral homes in local geographic areas. Unfortunately, the rule historically has not included other funeral service and merchandise providers, such as cemeteries and "third party sellers" of funeral merchandise. This is to the detriment of consumers.

My experience with cemeteries, in particular Corporate owned cemeteries, is that they overcharge for items such as grave markers, vaults and grave openings. Furthermore, and perhaps more importantly, the consumer has no alternative than to purchase the grave opening from the cemetery at which they wish to have the burial, leaving them with no alternative than to pay the inflated price.

In addition, in my experience, some cemeteries preclude me, and other sellers, from competitive grave marker sales (bronze markers and granite monuments) by charging highly inflated prices for such items as administrative fees, inspection fees, installation supervision fees, etc., that the cemetery may require for the installation of a memorial. Even if I install the memorial myself, many of the fees apply. When adding their "handling fees", I simply cannot compete.

Please consider expanding the Funeral rule to include all funeral providers, with special investigation of cemetery sales practices, rules and regulations.

I believe that this is an area of widespread abuse to the American Consumer. I also believe that the only reason that there are not more complaints, is because people are so exasperated with their loss they simply "just want to get it over with".

Thank you for your consideration.

Sincerely,

Kevin M. Bean
Reading, Pennsylvania