The memo accurately states the FTC requirements. What
astonishes me,
however, is that the MFDA failed to take the opportunity to:
A. Explain to their members why it would be a good thing to be open
about
their prices
B. Suggest that, even though the FTC Rule does not require faxed or
mailed
GPLs, that it would certainly be in the funeral homes' best interest to
do
so. Why? Because it would show they have nothing to hide.
As the person who made the "allegations" of Funeral Rule violations in
the
New Bedford survey to which this memo refers, I am delighted that they
know
we're watching. I'm really, really disappointed, though, that the
reaction
seems to be advice on how to minimally comply with reasonable disclosure
requirements, rather than on anything else. Where's the advice to be
open
and honest to everyone as a matter of course in business? Where is the
advice to make sure your GPL is always compliant, because your customers
deserve it?