If the GPL does not list the retail prices of the caskets offered by the funeral home, a separate Casket Price List must be prepared. This price list is far less complicated than the GPL. Although there are certain items which must appear on the list, there are no mandatory disclosures required on the Casket Price List.
Please note that the amended Funeral Rule made no modifications in the content or construction of Casket Price Lists or their distribution requirements.
At the top of the Casket Price List, the following three items should appear:
The full name of the funeral home must be placed on the Casket Price List. Unlike the GPL, it is not necessary to list the address and phone number for the funeral home on the Casket Price List.
The caption describing the list as the "Casket Price List" should also be printed on the top of the list.
The date that the Casket Price List became effective should be printed on the list. We again advise you to note next to the effective date that the prices are subject to change without notice.
All caskets and alternative containers that a funeral director has in stock for sale or that are part of his regular offerings must be listed on the Casket Price List, together with the retail price of each. Caskets which require special ordering need not be listed on the price list. There are no requirements regarding what order the caskets and containers must be listed nor are there any requirements concerning what types of caskets must be stocked (although an alternative container or unfinished wood box must be readily available if direct cremation is offered). If a casket is temporarily out of stock, it is not necessary to revise the Casket Price List. A funeral director may simply inform the consumer that the casket is presently not available.
In listing the caskets and alternative containers, you must provide a brief description of the exterior construction and the interior lining. With metal caskets, you should list the gauge of the metal. If there is prominent exterior trimming or coloring, this should be noted. There is no requirement that the manufacturer, model name or model number be identified.
The following provides an example of how casket offerings may be presented:
Solid Walnut, Gold Pin Stripe, Beige Velvet $___________
White Pine, Silver Crepe $___________
Cloth-covered Softwood, White Twill $___________
32 oz. Copper, Silver Beige Velvet $___________
48 oz. Bronze, Champagne Velvet $___________
16 ga. Steel, Sutter Bronze, Champagne Velour $___________
16 ga. Steel, Beige Velvet $___________
20 ga. Steel, Light Grey, Ivory Crepe $___________
Alternative Container, Cardboard $___________
Although the standard method of presenting casket prices to consumers is by means of a typed or printed Casket Price List, the Rule does permit alternative formats such as binders, notebooks, brochures and charts. As long as these alternative formats contain the same information as set out above, they will meet the requirements of the Rule.
An issue we have not seen addressed by the FTC is whether a funeral home could adopt a format which consisted of simply placing price cards in each casket set out for display. Because of the vagueness of the rule, there is an argument that this alternative method would be permissible. Nevertheless, we would advise against its use. The FTC could well maintain that the Rule requires all casket prices be assembled together, whether on a Casket Price List or in a notebook or binder. The use of separately placed cards in caskets could be viewed as defeating the consumer's ability to compare prices of the various caskets offered. Therefore, we strongly suggest that any alternative format adopted by funeral directors be constructed so that the prices of all caskets are readily available to the consumer.
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