Funeral Homes Editing and Proofreading Services

Some sentences on a funeral home's price list are not written by the funeral home. Three of them are examined here, and two carry an instruction to alter them in stated circumstances. The first sits on the general price list.

Under 16 CFR 453.4(b)(2)(i)(A) that disclosure opens "The goods and services shown below are those we can provide to our customers. You may choose only the items you desire."¹ The third sentence begins "If legal or other requirements mean you must buy any items you did not specifically ask for".¹ It ends with a promise to "explain the reason in writing on the statement we provide describing the funeral goods and services you selected."¹

The alteration the first passage requires

That paragraph does not stop at three sentences. Where the charge for the services of funeral director and staff cannot be declined by the purchaser, a further sentence goes between the second and third.¹ It reads "However, any funeral arrangements you select will include a charge for our basic services."¹ A provider whose fee includes a charge for the recovery of unallocated overhead may add the words "and overhead" after "services".¹ The disclosure therefore runs to three sentences or four, according to whether the charge can be declined.

The second passage, and the words a state can remove

The second sits beside the price shown for embalming. Under 16 CFR 453.3(a)(2)(ii) it reads "Except in certain special cases, embalming is not required by law. Embalming may be necessary, however, if you select certain funeral arrangements, such as a funeral with viewing."²

A third sentence addresses the reader who does not want embalming.² It reads: "If you do not want embalming, you usually have the right to choose an arrangement that does not require you to pay for it, such as direct cremation or immediate burial."² The same paragraph then releases five words from the opening. The phrase "except in certain special cases" need not be included where state or local law in the provider's area does not require embalming under any circumstances.²

The third passage

The third sits on the itemized statement of goods and services selected. Under 16 CFR 453.5(b) that statement carries a passage of three sentences.³ It opens "If you selected a funeral that may require embalming, such as a funeral with viewing, you may have to pay for embalming."³ The middle sentence covers embalming the customer did not approve, and the passage ends "If we charged for embalming, we will explain why below."³

A fee disclosure with two alternative versions

16 CFR 453.2(b)(4)(iii)(C) gives the provider a choice of two disclosures.⁴ The first carries the price for the basic services of funeral director and staff, together with a list of the principal basic services provided.⁴ Where the charge cannot be declined by the purchaser, that version adds "This fee for our basic services will be added to the total cost of the funeral arrangements you select."⁴ A charge that cannot be declined also carries a condition, because the quoted price "shall include all charges for the recovery of unallocated funeral provider overhead."⁴

The second version applies where the fee is built into casket prices. The list then reads "Please note that a fee of (specify dollar amount) for the use of our basic services is included in the price of our caskets."⁴ Two sentences complete that version, one adding the same fee where the customer supplies the casket, and one describing the services included.⁴

What happens when the same information is spoken

The Rule also governs the telephone. Under 16 CFR 453.2(b)(1) a provider tells callers who ask about its offerings or prices "any accurate information from the price lists described in paragraphs (b)(2) through (4) of this section".⁴ The same sentence continues, "and any other readily available information that reasonably answers the question."⁴

On November 20, 2024 the FTC published a staff report on an undercover phone sweep of 278 randomly selected funeral providers, called between February and December 2023.⁵ Twenty-one, seven percent, failed to give pricing during business hours, and seventy-three, twenty-six percent, failed after hours.⁵ Half the providers called "answered at least some questions about pricing with estimates or ranges, rather than actual prices."⁵ An earlier FTC post, from January 25, 2024, listed seven compliance points from undercover calls placed during 2023.⁶ The first was "Respond accurately when people call with price questions."⁶

What the provider settles, and what is left on the page

What a provider offers and what it charges are the provider's own decisions. We give no legal advice and we do not tell a provider whether a document complies with the Rule. The provider makes those judgments.

Where a sentence the Rule prescribes appears in different words, what is on the page is a paraphrase of it. Prices are compared between the general price list and the itemized statement. A parenthetical instructing the drafter to specify a figure sometimes survives into print, where it is plain on the page. Anything we receive is treated as confidential.

Under 16 CFR 453.6, a provider retains copies of the price lists "for at least one year after the date of their last distribution to customers."⁷ Each statement of goods and services selected is kept for at least one year from the arrangements conference.⁷ The FTC's guidance says the list goes to anyone who asks in person about funeral goods or services.⁸ A provider must "physically offer consumers a General Price List that they can keep and take home with them."⁸