Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00038

Submission Number:
00038
Commenter:
Gerald Serotta
State:
Maryland
Initiative Name:
Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163
To whom it may concern: I am very familiar with the issues involved in the case of the need for divestiture in the merger of funeral consortiums in our area where I have served as a Rabbi for 31 years. 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. However, 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 deter the important competition provided by the Jewish Funeral Committee of Greater Washington contract. I urge the Commission to revise the proposed consent decree and require the divestiture of Hines Rinaldi. Many thanks for your consideration and your work. Sincerely, Rabbi Gerald Serotta ___________________