Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00051

Submission Number:
00051
Commenter:
Bruce Kutnick
State:
Maryland
Initiative Name:
Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163
I want to thank the Commission for the time and effort that it has put into the 'regional market' for funeral services that is the Washington area Jewish community, regarding SCI's merger with Stewart Enterprises. I appreciate the FTC's recognition of the need for action to preserve competition -- and with it, the continuation of the consumer-oriented 'group contract' of the Jewish Funeral Practices Committee of Greater Washington. Over the past several years I used this "group-contract" with Hines-Rinaldi Funeral Home to arrange for the burial of my in-laws. However, the proposed remedy of requiring the divestiture of Edward Sagel Funeral Home is wholly inadequate to protect competition in the market. Currently, SCI owns both funeral homes, Sagel and Danzansky. Sagel is basically a storefront and lacks a chapel and adequate facilities to handle the deceased-for washing and dressing the body-in accordance with Jewish tradition. It is wholly dependent on the SCI funeral home -- Danzansky -- for these services. 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 consumer protection and competition provided by the Jewish Funeral Practices Committee of Greater Washington contract. I urge the Commission to revise the proposed consent decree and require the divestiture from SCI of the full service Hines-Rinaldi Funeral Home and not Sagel. Thank you for your consideration of my comments. Bruce Kutnick