When the FTC announced its routine review of the Funeral Rule in 2020, the Funeral Consumer Alliance and about half the country’s state attorney generals responded with complaints about online advertising by the funeral industry. The criticism of funeral home
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Funeral Rule Revisions: Minority Communities
The last section of the Funeral Rule notice (Issues 37-40) raises questions whether there are funeral provider practices that disproportionately affect minority communities. Again, we are not quite sure the intent of the FTC when raising these questions. Concerns have…
Funeral Rule Readability: What Makes for a Good GPL?
The next-to-last section of the Funeral Rule notice (Issues 32-36) deals with what the FTC calls Price List Readability. This seemed to us as a very nebulous phrase, and so we searched “Price List Readability” in the context of…
Funeral Rule’s Embalming Disclosure: When Required by State Law
Issues 28 through 31 of the FTC Funeral Rule notice concern the embalming disclosure. Consumer advocates are pressing to have the Funeral Rule be more specific about when state law does or does not require embalming. For states that require…
The Funeral Rule Changes: Alternate Forms of Disposition
Issues 23 through 27 of the FTC Notice to amend the Funeral Rule raise questions concerning the new alternative forms of disposition: alkaline hydrolysis and natural organic reduction. For the most part, consumer advocates have embraced these new forms of…
Funeral Rule Revisions: Reduced Basic Fees
The intent behind Issue No. 22 of the FTC Notice to revise the Funeral Rule has us a little perplexed. Funeral providers may charge a lower basic services fee for direct cremations and immediate burials. Issue 22 seems to be…
Funeral Rule Revisions: Incidental Costs Disclosure
For this post we are focused on Issues 18 through 21of the FTC’s Notice to revise the Funeral Rule. With these issues the FTC is responding to consumer advocates assertions that the GPL does not adequately disclose incidental costs…
Funeral Rule Revisions: Mark Up on Trade Services
The FTC’s second area of concern for Funeral Rule revisions is titled Crematory Fees and Additional Costs. For this post, we are going to look at Issues 16 and 17. Funeral consumer advocates are focused on the fact that…
FTC’s 40 Issues: Confirming Delivery of Price Lists to the Online Shopper
With Issues No. 10 through 15 of the FTC’s Funeral Rule notice, the agency begins inquiries on how to ensure the online shopper has access to all of the funeral home’s price lists before making any selections. Would it be…
The FTC’s Seven Areas of Concern: Funeral Rule Revisions
As discussed in our prior post, the FTC’s rulemaking notice for amending the Funeral Rule requests public comment on 40 Issues. Those 40 issues are grouped by the FTC in the following 7 categories of potential amendments:
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