Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00023

Submission Number:
00023
Commenter:
robert rovinsky
State:
District of Columbia
Initiative Name:
Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163
While the FTC was correct in recognizing that the merger of SCI and Stewart would harm competition in the Jewish funeral home market in the DC/MD area, it fails to recognize that the proposed remedy of requiring the divestiture of Edward Sagel Funeral Direction is wholly inadequate to protect competition in the market. Sagel is basically a storefront and lacks a chapel and adequate facilities to handle the deceased. It is wholly dependent on the SCI funeral home -- Danzansky -- for these services. Its market share has fallen from 25% to 11% in the last three years. If it is divested it is highly unlikely to remain an effective competitor in the market. Moreover, with the control of both Danzansky and Hines Rinaldi, SCI will still have the incentive and ability to impair the important competition provided by the Jewish Funeral Practices Committee of Greater Washington contract. This competition has greatly lowered the cost of traditional Jewish funerals and most Jews need and want this option. I urge the Commission to revise the proposed consent decree and require the divestiture of Hines Rinaldi.