FTC Staff Comment to the Hon. Kirby Holmes Concerning Michigan Substitute H.B. 4588 to Regulate Pre-Need Funeral Goods and Services

F<..-dcral Trade Commission
Qeveland Rerjonal OffK:e
Suik 500
The Mall Buildin~
118 Sl. Clair A\wnue~
CJc~\!dand, Ohio 44114
An~i1 Cocf.~ (216) 522-42Oi
Senator Kirby Holmes
Senate State Affairs, Veterans,
and Transportation Committee
Post Office Box 30036
Lansing, Michigan 	48909
Dear Senator Holmes:
April 7, 1986
The Federal Trade Commission's Cleveland Regional Office is pleased to respond
to your invitation to comment on Substitute House Bill 4588, which is under consideration
by the 	Michigan Legislature.l! 	In these comments, we first discuss certain general
competitive considerations raised by the proposed legislation concerning the sale of "pre-
need" 	funeral goods and services. 	We 	then specifically address the issues of trust
arrangements 	and 	alternatives 	to 	them, 	restrictions 	on 	who 	can be 	escrow agents,
restrictions on interest rates, and the requirement that a specific provider be identified
at the inception of the contract.
The Federal Trade Commission seeks to promote competition among members of
licensed professions to the maximum extent compatible with other legitimate state and
federal goals. 	For several years, the Commission has been investigating the effects of
restrictions on the business practices of professionals, including optometrists, dentists,
lawyers, physicians, 	funeral directors,and others. 	Our goal is to identify and seek
removal of restrictions that impede competition, increase costs, and harm consumers
without providing countervailing benefits.
The Commission has pursued this goal actively in the funeral industry. 	As you
may be aware, the Commission's Funeral Industry Trade Practices Rule ("Funeral Rule"),
16 C.F .R. Part 453, became effective in full on April 30, 	1984.' 	The purpose of the
Funeral ~ule is 	to permit increased competition and consumer choice in the funeral
industry 	by 	facilitating 	informed purchasing decisions 	by 	consumers. 	Among other
things, 	the Funeral Rule 	requires providers of funeral goods and 	funeral services to
disclose 	detailed 	information 	about 	pric~s and 	legal 	requirements 	to 	purchasers 	of
funerals.
1/ 	These comments represent the views of the Cleveland Regional Office and of the
Bureaus of Competition, Consumer Protection, and Economics of the Federal Trade
Commission and do not necessarily represent the views of the Commission or any
individual Commissioner. 	The Commission, however, has authorized the staff to
submit these comments.

Senator Kirby Holmes 	Page 2.
Substitute House Bill 4588 sets up an extensive regulatory scheme for the "pre-
need" (or prepaid) sale or funeral goods and services. 	The bill requires sellers and
providers of pre-need funeral goods and services to register with the Department of
Licensing and Regulation ("Department"), to oomply.with detailed escrow requirements
goveming 	the 	limited 	permissible 	arrangements, 	to 	maintain 	extensive 	records with
respect to all escrow arrangements, and to adhere to the limitations set forth in the bill
on the amount of commission that can be charged on a sale as wen as the "interest rate"
that can be applied when the purchaser pays over a period of time. 	Also, the bill requires
the designation of named providers at the time the contract is entered into, regulates
cancellation of contracts, gives the purchaser a ten-day right to rescind the contract,
allows 	the 	Department 	to 	promulgate 	rules 	and 	regulations 	that 	would 	govem 	the
solicitation of pre-need sales, and sets up an enforcement mechanism.
We believe that the following comments, which discuss in general the regulatory
scheme established by the bill as well as several specific restrictions, will assist you in
evaluating the bill's possible effects on competition and consumers.
A. 	General Comments.
Pre-need 	sales 	of 	funeral 	goods 	and 	services 	are 	a 	rapidly 	growing 	way 	of
marketing many of the goods and services involved in funerals. 	These sales appear to
have 	significant 	potential 	for 	offering 	consumers 	opportunities 	they 	did 	not 	have
before. 	For example, pre-need arrangements enable consumers to make buying decisions
without the time or emotional pressures associated with at-need purchases.
Because 	pre-need sales 	are 	relatively 	new, 	providers 	are 	still leaming which
methods of marketing are most feasible and consumers are stilileaming which are most
useful. 	It is especially important to allow a new form of marketing goods and services,
such as pre-need sales, to develop without unnecessary or overly burdensome regulation
so that consumers can reap the benefits of new, creative forms of competition. Through
innovation and experimentation, these benefits can become available to consumers.
Restrictions 	on 	the 	business 	practices 	of 	licensed 	professionals 	can 	reduce
competition 	by 	preventing 	the 	introduction and development of innovative forms of
practice that may be more efficient, provide comparable quality at lower prices, and
offer 	competitive 	alternatives 	to 	traditional 	providers. 	.For 	example, 	in 	a 	case
challenging 	various 	ethical 	code 	provisions 	enforced 	by 	the 	American 	Medical
Association (AMA), the Commission found that AMA rules prohibiting physicians from
working on a salaried basis for a hospital or other lay institution, and from entering into
partnerships 	or 	similar 	business 	relationships 	with 	non-physicians, 	unreasonably
restrained competition 	and 	thereby 	violated 	the 	antitrust laws. y 	The 	Commission
American Medical Association, 94 F.T.C. 701 (1979), aff'd, 638 F.2d 443 (2d Cir.
1980), 8frd memo by en equally divided Court, 455 U.s. 676 (1982).

Senator Kirby Holmes 	Page 3.
concluded that the AMA's prohibitions kept physicians from adopting more economically
efficient 	business 	formats 	and 	that, 	in 	particular, 	these 	restrictions 	precluded
competition 	by 	organizations 	not 	directly 	and 	~ompletely 	under 	the 	control 	of
physicians. 	The Commission also found that there were no countervailing procompetitive
justifications for these restrictions. y
We 	also 	recognize 	that 	Michigan has 	a legitimate 	interest 	in 	protecting 	the
investment of pre-need purchasers and in preventing fraudulent or deceptive practices.
Most important, because pre-need purchasers may pay a substantial sum of money for
goods or services that may not be provided for many years, there is a need to ensure that
there will be funds and providers to deliver these goods and services at the time they are
required. 4/
However, 	when adopting regulatory measures in order to protect the pre-need
consumer's investment or prevent abuses, the Legislature should at the same time be
aware that consumer injury may occur when regulation stines price competition and
inhibits 	innovation. 	The 	appropriate 	way 	to 	acllieve 	the 	optimal balance between
protecting 	pre-need 	pur~hasers on 	the 	one 	hand, 	and 	facilitating 	competition 	and
innovation 	on 	the 	other, 	is 	to strive 	to find 	the least 	restrictive 	means 	to protect
consumers 	against 	insolvency, 	fraud, 	and 	deceptive 	practices. 	Balancing 	these
considerations in this way assures that consumers will receive adequate protection while
allowing the 	market 	to function in the freest possible 	manner. 	This is particularly
important when dealing with a relatively new and growing form of distribution, such as
pre-need 	funeral 	sales, 	where 	regulation 	may 	have 	a 	disproportionate 	impact 	on
innovation.
In the remainder of this letter, we will comment on specific portions of the bill in
light of these general comments.
1/ 	In 	another 	example, 	the 	Commission 	recently 	issued 	a 	notice 	of 	proposed
rulemaking 	for 	a 	trade 	regulation 	rule 	that 	would 	preempt 	state 	laws 	and
regulations 	that 	ban, 	among 	other 	things, 	employment 	or 	other 	business
relationships 	between 	optometrists 	and 	non-optometrists. 	In 	its 	notice, 	the
Commission stated that public restraints on forms of ophthalmic practice appear to
increase prices without providing offsetting public health or safety benefits. 	50
Fed. Reg. 598, 599-600 (1985).
~ 	On the other hand, one of the factors that led to the promulgation of the Federal
Trade Commission's Funeral Rule - 	the particular vulnerability that relatives or
close friends of a recently deceased person may have to certain kinds of pressure
because of grief and a short time to make arrangements - 	is not present to nearly
the same extent in pre-need sales.
!,I
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Senator Kirby Holmes
B. 	The Provisions Conceming the Disposition of Money Paid by Purchasers.
Page 4.
Substitute House Bill No. 4588 sets up detailed procedures for the handling and
accounting for funds paid by pre-need purchasers, apparently to ensure that adequate
funds will be available at the time the funeral goods and services will be needed. 5/ The
linchpin of these procedures is a detailed escrow arrangement, often referred to as a
"trust requirement." 	While the bill in its present form would ensure the availability of
funds, it would do so at a significant - 	and, perhaps, unnecessary - 	cost to consumers.
The 	bill states 	that 	"all 	funds 	received in connection with a 	prepaid funeral
contract shall be held in escrow." 6/ 	It then provides that "an additional commission of
not more than 10% of the contractprice" may be ch8l1l:ed, and that the commission is not
subject to the escrow requirement. 7/ 	Finally, it provides detailed procedures for the
handling and disbursing of the funds kept in escrow. 8/ Thus, while the bill uses language
similar to that used in the "100 Percent Trust" laws (laws requiring that 100 percent of
the f?re-need funds received be put in trust), it is really a 91 percent trust law - 	i.e., it
reqwres at least 91 percent of the total funds paid to be put in trust.
This particular escrow arrangement will probably provide adequate assurance that
there will be funds available to pay for the goods and services at the time the contract
beneficiary dies. 	However, it may also unnecessarily increase the cost consumers incur
in purchasing funeral goods and services on a pre-need basis. 	We 	first address the
general impact of a trust requirement and then suggest an alternative way to guarantee
the performance of the pre-need seller which avoids some of the anticompetitive risks
posed by a trust requirement.
§./ 	The bill includes several provisions apparently aimed at ensuring that there will be
funds and providers to deliver the goods and services at the time of need. 	See, for
example, Sections 6 and 8 (requiring registration and reporting by contract sellers
and providers), Section 9 (requiring reassignment of contracts by any provider who
goes out of business), and Section 11 (requiring that a provider be designated and
obligated at the inception of the contract).
2.! 	Section 12( 1)
1/ 	Id.
!/ 	Section 12(2) - (11). 	II
1

Senator Kirby Holmes
1. 	The Impact of a Trust Reguirement.
Page 5.
Some 	states 	have 	determined 	that 	trust 	requirements 	are 	an 	appropriate
regulatory 	mechanism 	for 	protecting 	the 	pre-need 	consumer's 	investment, 	and 	for
preventing 	fraud 	and 	other 	abuses. ~ 	Nevertheless, 	a 	trust 	requirement 	- 	most
obviously, 	a 	100 	percent 	trust 	requirement 	- 	can 	have 	unintended 	anticompetitive
consequences 	that injure consumers. 	Thus, although a trust requirement will provide
some benefits to consumers, the Legislature will want either to select carefully the level
of trust to avoid competitive harm or to consider alternative arrangements that provide
the same benefits but do not have the same anticompetitive potential.
While Substitute House Bill 4588 sets a trust requirement that is less than 100
percent, the potential problem that it poses is one similar to that raised by a 100 percent
trust 	requirement. 	One 	hundred 	percent 	trusts 	require 	that 	all 	funds 	paid 	by 	the
consumer must remain in a trust fund until death occurs. 	Under this requirement, the
seller 	cannot 	recover 	its 	financial 	outlay 	for 	overhead, 	selling 	and 	administrative
expenses, 	or a 	competitive 	rate of retum until an uncertain, possibly distant future
date. 	Many potential sellers may be unwilling or unable to cover the initial costs of pre-
need sales (either by using their own capital or by financing these costs) for a lengthy,
indefinite period of time. 	This requirement may therefore discourage competitors from
entering the pre-need market. 	Fewer sellers and the resulting reduced competition in
the 	pre-need 	market can cause injury to consumers by depriving them of the lowest
prices for the goods and services they wish to purchase and of the full array of pre-need
alternatives and pricing options that would otherwise be available.
A 	trust 	requirement 	that 	is 	less 	than 	100 	percent, such 	as 	one· that 	simply
specifies the amount of money that must be put in trust (for example, the wholesale cost
of the goods), may still raise competitive concems. 	If the amount of money required by
law to be placed in trust, added to the amount the seller needs up front, exceeds the
price 	that 	the 	market 	would 	set 	for 	the 	whole 	transaction 	(absent 	legislative
intervention), then the trust requirement has the effect of raising the price consumers
must 	pay for 	the goods and services. 	If this increase in price is not offset by an
increased benefit to the consumer (i.e., a reduction in the risk of 	non-performance),
then the 	trust 	requirement 	will 	make 	the 	pre-need 	goods and 	services unattractive
to 	the 	consumer. 	As 	a 	result, 	a 	source 	of competition 	for 	at-need sellers 	will be
~ 	There are myriad ways in which a trust requirement might be set up, inclUding
requiring that some percentage of the retail price for the goods and services be
placed in escrow, or requiring that some percentage of the wholesale price of the
goods and services be placed in escrow. 	i
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Senator Kirby Holmes 	Page 6.
discouraged.1.Q./
Ideally, if a trust requirement is to be imposed, it should be set at a level that will
provide 	protection 	to 	consumers 	at 	the 	level 	they 	desire 	while 	having 	the 	least
competitive impact. 	This means the Legislature must lUldertake the task of determining
how much money is adequate to ensure the achievement of that level of protection. This
task is difficult, and 	it 	is practically impossible 	without extensive 	investigation and
study. 	In 	addition, 	as 	market 	conditions 	change, 	the 	optimal trust level may well
change. 	If the Legislature wishes to establish a fixed trust level that will continue to
protect consumers but not raise prices unnecessarily even as market conditions change, it
should either routinely reevaluate this level or set up an administrative mechanism to do
so. Both of these alternatives are costly in time and tax dollars.
2. 	An Alternative Guarantee.
Rather 	than 	attempt 	the 	difficult 	task 	of 	determining 	the 	precise 	trust
requirement that will adequately protect consumers with the minumum adverse impact
on 	competition, 	the 	Legislature 	may 	wish to examine an alternative guarantee, the
performance bond.
In analogous types of sales where delivery is deferred or occurs over an extended
time, performance bonds have been an effective means of protecting the consumer's
investment. 	For example, in three recent Commission cases, health spa businesses were
charged 	with, 	among 	other 	things, 	failing 	to 	fulfill 	contracts 	with 	customers 	and
retaining 	customers' 	money 	without 	offering 	or 	making 	refunds•.!!I 	The 	consent
judgments in those cases prohibit the spa operators from accepting any payment for a spa
membership in advance of providing promised services unless performance bonds have
been obtained. 	The consent judgments specify that the bond amount must be for at least
$50,000 or enough to provide refunds to all health spa members in the event that a spa
fails to open or closes before all the services are provided.
A trust requirement can affect price in less obvious ways. 	For example, a high
trust requirement - 	combined with a cancellation clause like that found in Section
13 of the bill - 	will indirectly raise costs. 	One option that is open to sellers who
want more money at the inception of the contract is to borrow the money, using the
escrow account as a form of security. 	The seller will include the cost of borrowing
in the cost of the pre-need goods and services. 	If the consumer can cancel the
agreement at will, the lender will feel less secure and raise the interest rate the
seller pays. 	This additional cost will, of course, be passed along to the consumer in
the form of a higher price for pre-need goods and services. 	Competition with at-
need sellers will &gain be reduced.
!!! 	FTC v. Lady Venus Centers, Inc., No. 3-84-0158 (M.D. Tenn. Feb. 16, 1984); FTC v.
Tyler-Radcliffe Co., Inc., No. 3-84-0159 (M.D. Tenn. Feb. 16, 1984); FT-C v. Thor
Enterprises, Inc., No. 84-212l-MA (W.D. Tenn. Feb. 16, 1984).
I
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Senator Kirby Holmes 	Page 7.
A performance bond can be written to ensure that the guarantor stands ready to
pay for the goods and services if the seller cannot provide them, so that the consumer is
protected 	from 	seller 	default 	whether 	it 	is 	caused 	by 	fraud 	or 	insolvency. 12/ 	In
addition, 	because 	guarantors 	compete 	among 	themselves 	for 	the 	performance bond
business, the 	price 	of 	these 	bonds 	and 	the 	requirements 	on 	sellers (whether they be
escrow arrangements or otherwise) 	will be set 	in the 	most efficient 	manner by the
market. 	Guarantors will be able to determine requirements individually for each seller,
providing adequate protection at the lowest cost. 11/
If 	the Legislature 	elects 	to 	require 	performance 	bonds, 	it 	will 	no longer be
necessary to restrict the money a seller can keep for its own use at the time the contract
is 	signed 	(the 	commission). 	We 	believe 	that 	the 	restriction 	on 	commission 	is an
tmdesirable feature of the bill, one that may potentially injure consumers. To the extent
that a commission is inadequate to cover the cost of overhead, selling and administrative
expenses, 	and 	the 	competitive 	rate 	of ::-eturn 	that sellers believe 	they need at the
inception of the contract, 	they are either discouraged from 	entering the 	market or
forced to raise the price of the pre-need goods and services to compensate for this. 	In
either case, consumers will be disadvantaged. 14/ 	A performance bond eliminates any
need for regulating the commission and therefore benefits consumers by reducing the risk
that unnecessary costs will be incurred and that competition will be weakened.
Thus, a requirement that pre-need sellers obtain performance bonds to guarantee
the 	delivery 	of 	prepaid 	funeral 	goods 	and 	services 	is 	a 	viable, 	less 	costly, 	and
procompetitive alternative that the Legislature should consider.
12/
.!.i/
The best performance bond for consumers is not necessarily one with 100 percent
coverage of the goods and services promised in the contract. 	The Legislature may
want to consider whether some reduction of a performance bond requirement from
100 percent will save consumers more money in fees for the bond than it will cost
them in lost goods and services.
One particular seller may be a better risk than a second one, for example, because
of a large fixed-asset base. 	If the lower risk seller is charged a lower fee for a
performance bond, the seller can pass that savings along to consumers. 	In addition,
it may be reasonable to put fewer restrictions on the lower'risk seller, for example,
a 	lower 	escrow 	requirement. 	This 	can only be dpne 	if sellers are dealt 	with
iridividually.
On its face, Section 12 of Substitute House Bill 4588 sets a maximum "price" for
the allowable commission. 	If, in fact, the 10 percent limit were substantially in
excess of the total of the cost of overhead, selling and administrative expenses, and
the competitive 	rate of ~etum that 	the seller required at the inception of the
contract 	to run its business 	most efficiently, there would be no harm because
competitive t'orces would drive down the amount of commission actually charged.
However, a 10 percent commission may not provide an adequate amount of money
at 	the 	time 	the 	contract 	is 	initially 	signed 	for 	every 	legitimate 	method 	of
marketing pre-need funeral goods or services. 	If the initial compensation (the
commission) is inadequate, sellers either must finance their need for cash (and pass
that additional cost along to consumers) or they simply may not enter the market
(reducing competition).

Senator Kirby Holmes
c. 	The Limitation on Who Can Be an Escrow Agent.
Page 8.
Section 	12(2) 	of Substitute House Bm 4588 	lists institutions 	that 	may act as
escrow agents. 	Various financial institutions are allowed to act a.s escrow agents and a
non-profit corporation set up by 250 funeral homes or 250 cemeteries ma.y also act as the
escrow agent. 15/ 	While 	the bill contemplates that there will be sellers other than
funeral homes and cemeteries, it Goes not allow any other group of sellers to set up a
similar non-profit corporation as an escrow agent.
If 	the 	Legislature 	elects 	to 	keep 	an 	escrow 	arrangement, 	we 	believe 	the
designation 	of 	responsible 	financial 	institutions 	as 	escrow 	agents 	is 	meritorious.
However, we Me concerned that 	the :-estriction that non-profit groups functioning as
escrow agents must be composed of at least 250 funeral homes or cemeteries may be
more restrictive than necessary. 	While we cannot advise the Legislature on the number
of firms that need to be included in such a non-profit organization, we would encourage
the Legislature to consider whether organizations with fewer than 250 members would be
financially 	sound 	enough 	to 	protect 	the 	funds 	it 	holds 	in 	escrow. 	We 	would 	also
encourage the legislature to consider whether it might be advantageous to permit both
funeral homes and cemeteries to participate jointly in a single non-profit organization.
Further, 	we 	are 	concerned 	~hat, under 	the 	bill, 	pre-need sellers 	who do not
operate funeral homes or cemeteries (e.g., organizations that sell only funeral goods or
organizations that sell both funeral goods and services but always contract with providers
for delivery) are not able to form or participate in non-profit organizations that provide
escrow 	services. 	If 	there 	are 	:;ignificant 	cost 	advantages 	from 	using a 	non-profit
organization rather than a finalicial institution as an escrow agent, the failure to provide
this option to alternative sellers of pre-need funerals could place these sellers at a
competitive disadvantage.
D. 	The Limitation on the "'Interest"
ontracts Paid Over Time.
Substitute 	House 	Bill 4588 	limits to 	10.5 	percent the "interest" that 	may be
charged on a ;:>re-need contract that the consumer pays in.installments. 	Assuming the
interest ·rate is clearly disclosed to the consumer before the contract is signed (as federal
law 	requires~ 15 	U.s.C. § 1601, 	et seQ.), 	we fail 	to see how 	this provision protects
consumers from fraud or deception, whereas it may have a substantial anticompetitive
impact.
ill 	According 	to 	our 	information, 	there 	are 	currently approximately 2100 	funeral
directors 	licensed 	in 	the 	State 	~f 	Michi{!an, 	but 	only 	about 	285 	licensed
cemeteries. 	This number does not include cemeteries operated by municipalities or
religious organizations because f:~ese types of t:!emeteries are not licensed under
Michigan law.

Senator Kirby Holmes 	Page 9.
If the market interest rate again rises above 10.5 percent, as it has done in the
recent past, then the bill will artifically set a below. market ceiling on the interest that
can be charged, and sellers will find offering this service financially unattractive. 	This
will discourage sellers from offering the service in Michigan, thus depriving consumers of
the additional choice of paying on an installment bas~. 16/ 	Competition with at-need
sellers will be further weakened. 	-
E. 	The Requirement that a Specific Provider Be Identified and Obligated
Before the Consumer Pays.
Substitute House Bill 4588 requires that guaranteed price contracts for pre-need
goods and services designate a specific provider, and that the seller have a contract with
that 	provider 	to 	supply 	the 	goods 	and 	services 	before 	the 	consumer 	pays 	any
consideration. 17/ 	This provision presumably is intended to ensure that the consumer
receives the goods and services when they are required.
We are concerned that, although this provision may not materially handicap sellers
in 	the 	pre-need 	market as this 	market is currently structured, the requirement may
discourage innovation that could be of substantial benefit to consumers. 	For example, if
a seller wished to offer pre-need goods and services that a purchaser could use anywhere
in the State of Michigan, or even in the entire United States, this provision in Substitute
House 	Bill 4588 	would 	make that virtually 	impossible Wlless the seller cOuld 	find 	a
provider who could deliver service over a very large area. 	More mobile consumers could
be deprived of the benefits of pre-need sales that are available to consumers who expect
to stay in one location for the remainder of their lives. 	By reducing the demand of
mobile 	consumers, 	this 	provision 	would 	reduce 	the 	competitive 	impact 	of pre-need
sellers. 	.
This provision could have the curious effect of allowing the consumer to pay for
pre-need funeral goods and services in installments only by setting up two separate
transactions (i.e., by negotiating the loan from a totally separate entity that is not
subject to the 	10.5 percent interest rate limitation, such as a consumer finance
company), but prohibiting the consumer from achieving an identical result in the
more convenient form of having one seller for both the sale and the financing.
111 	Section 11. 	A guaranteed price contract is one that sets a fixed price for the goods
and services and does not allow for the imposition of any additional charges.

Senator Kirby Holmes 	Page 10.
The Legislature may wish to consider whether there is a less restrictive way to
provide consumers with adequate guarantees of performance, particularly because this
provision may be wholly or partially redundant when coupled with a performance bond or
an 	adequate 	trust 	requirement. 	For 	example, 	it· may 	be sufficient 	to 	identify 	an
association 	or 	organization of providers that 	can 	fumish 	the goods 	and services in
multiple 	locations. 	Furthermore, 	a 	performance 	bond 	(discussed 	above) 	could 	be
structured to require the guarantor to pay for performance even if the person making the
arrangements for the contract beneficiary was forced to locate another provider because
the seller failed to perform. 	In this case, although consumers may be inconvenienced,
they would not lose any money, making it unnecessary to identify a specific provider at
the inception of the contract.
F. 	Conclusion.
We have focused our comments solely on those portions of slbstitute House Bill
4588 that appear to be of particular competitive impact. 	We do not necessarily endorse
the remaining provisions of the bill, but rather express no opinion on them. 	We hope that
our comments conceming the competitive and consumer protection aspects of certain
types 	of pre-need 	trust 	agreements, 	restrictions 	on 	commission, 	escrow agents and
interest, and the requirement to designate a provider will assist you in your deliberations
on Substitute House Bill 4588. 	We appreciate having had the opportunity to present our
views.
Sincerely,
/ 	/' 	;/~/.
, /. 	/ 	;;1'- '/'-. 	./!!,-(l/:;?it'..;;· 	~i 	:/~
" William W. Jacobs
Regional Director
Cleveland Regional Office