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1 Michael C. McCarey, Recommendations for a Final Funeral Practices Rule 1 (1981)

handle is hein.usfed/recffpr0001 and id is 1 raw text is: UNITED STATES GOVERNMENT DA,,:June 29, 1981 memorTndum REPLY TOMichael C. McCarey, Assistant Director ^nOF: for Professional Services ( ILA SUBJECT: Recommendations for a final Funeral Practices Rule TO: Commission The attached papers set forth the Funeral staff's recommendations for a final rule. I agree with the staff that a rule is needed and I fully support most of the provisions they have proposed. But several provisions go beyond what I feel is warranted and I do not support them. This memorandum is intended to explain where I differ with the staff. I also discuss why I join the staff in recommending that industry be permitted to use an alternative form for disclosing prices. This discussion is included because of staff's and my disagreement with the Deputy Bureau Director on whether an alternative form of price disclosure should be allowed. 1. General Analysis The proposed rule is based principally on the strategy that by making the market for funeral services more competitive, it will make it more efficient and more responsive to consumers' needs. But the rule also contains several provisions (discussed specifically infra) which reflect a skepticism that this market will ever become sufficiently competitive to respond adequately to consumers' needs. These provisions are attempts to guarantee through regulation benefits that a competitive market should, at least to some degree, bring about. This skepticism is understandable. The funeral industry will not become a better servant of consumers' needs until consumers1 resist being manipulated and begin to make purchase decisions that reward sellers who respond to their needs and 1 Or at least a substantial number of them. i Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan

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