Opinion 95-4

8UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
WASHINGTON, D.C. 20580
.. Division of
Marketing Practices
Mary S. Feinstein
Attorney
Direct Dial:
(202) 326-3064
August 15, 1995
Scott R. McCray
General Counsel
Vanguard America Co
P.O. Box 10223
Raleigh, NC 27605-0223
Re:
Vanguard's Trust 100 Marketing Program
D~ar Mr. McCray:
This letter is in response to your letter of July 24, 1995
about Vanguard's Trust 100 Marketing Program. I hope that this
letter provides an answer to the question you posed.
1. May your company, acting as a sales agent for several
funeral providers, use one generic general price list ("GPL")
the sale of funeral goods and services?
in
If your company is acting as an agent for funeral providers,
and is offering for sale funeral goods and services, it must
provide a GPL (and other price lists to the extent that they are
required) that meets the Funeral Rule's requirements. Each
funeral provider who agrees to be bound by the prices on such GPL
should list its name, address and telephone number on the GPL
even if one GPL is used. .Q.§.§.16 C.F.R. § 453.2(b) (4) (i) (C). As
noted in your letter, consumers must be allowed to itemize the
funeral goods and services selected.
I hope that this resolves this question. Please be advised
tnat the views expressed here are those of FTC staff. They have
not been reviewed, approved or adopted by the Commission, and
they are not binding upon the Commission. However, they do
reflect the opinion of those staff charged with enforcement of
the Funeral Rule.