Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163
The hallmark of FTC antitrust enforcement is realism about the real-world effects of a merger. That is why, commendably, the FTC has sought to prevent harm to the Washington area Jewish community as a result of SCI's merger with Stewart Enterprises. But, if harm is to be averted, the remaining competition must be real, not a shadow. The proposed divestiture of Edward Sagel Funeral Direction is insufficient. To preserve competition in the provision of traditional Jewish funeral services, a funeral home needs the facilities that are integral to such services. Sagel does not have them and is very unlikely to have the means to add them. To achieve the goal of effective competition to protect Jewish consumers in the Washington area, the FTC should require divestiture of Hines Rinaldi, which does have these facilities. Thank you for your consideration.