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1 Summary of Rebuttal Comments in Response to January 22, 1981: Federal Register Notice 1 (1981)

handle is hein.usfed/srcrfrn0001 and id is 1 raw text is: 
                                                  UNITED STATES GOVERNMENT

  oays: June 26, 18                        meporancum

  swo: Robert Schick, Gloria Cordes-Macklin, Pamela Coveney, and
        Curtis Yee, Attorneys, Division of Professional Services
sumawTcommendations   on funeral rule


   TO:Commission







      I.  Introduction

           This memorandum presents our recommendations for the final
      language of the funeral rule, based upon our analysis of the
      initial comments and rebuttal comments submitted in this matter
      pursuant to the Commission's January 22, 1981 Federal Register
      notice.  Attached as Appendix A to this memorandum is a side-by-
      side comparison between our recommended rule and the rule as it
      appeared in the Federal Register on January 22, 1981.  In our
      memorandum, we refer to the revised rule published by the
      Commission as the January 22 rule.  Also attached as Appendices
      B through G are model forms illustrating the appearance of price
      lists which would comply with the rule's requirements.

           As the Commission is aware, National Selected Morticians and
      the National Funeral Directors and Morticians Association
      submitted in their initial comments a proposed rule (the
      NSM/NFDMA proposal) for Commission adoption instead of the
      January 22 rule.  Before they did so, the Bureau and rulemaking
      staff reviewed the NSM/NFDMA proposal and stated our view that,
      taken as a whole, it addresses the primary abuses identified in
      the rulemaking record and meets the objectives of the funeral
      rule proceedings.  We added, however, that we would take into
      account comments submitted on all issues, including the NSM/NFDMA
      roposal,  before we made our final recommendation to the
      Commission.

           Consistent with that statement, we have examined all initial
      comments submitted, including the revised industry guides
      submitted by the National Funeral Directors Association
      (NFDA). While  the revised guides provide consumers with a
      higher degree of protection than the original guides proposed in
      October, 1980, they still do not provide a level of protection
      equivalent to that provided either by the January 22 rule or the
      NSM/NFDMA proposal.





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