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The ICCFA does what no cemetery or funeral home can do alone: We speak for the entire industry. Congress looks to us when an expert on our industry is needed. The ICCFA keeps members informed of relevant legislative and legal activities through several vehicles, including "Washington Report," a column that appears monthly in ICCFA Magazine and Wireless, a bi-weekly e-mail newsletter.
Some of the recent government, public affairs and legal advocacy efforts the ICCFA has undertaken on behalf of the profession include:
Troublesome New Tax Issue Emerges for 2013 (February 2013)
The Health Care and Education Reconciliation Act of 2010 created a new Medicare tax of 3.8% on certain individuals, estates and trusts for unearned income. The tax is effective for tax years beginning after December 31, 2012, and appears to affect income derived from qualified funeral trusts under IRC Sec. 685, and cemetery perpetual care funds under IRC Sec. 642(i). Should the “per beneficiary” approach be used for funeral trusts, there will likely be no tax because each beneficiary would be unlikely to earn more than $11,900 annual threshold amount to trigger the tax. However, cemetery care trusts are another matter that requires further scrutiny. The new Medicare tax has been codified in the Internal Revenue Code as section 1411.
The ICCFA, through its Government and Legal Affairs Committee, is in the process of drafting comments for submission to the Internal Revenue Service to urge that the “beneficiary” method of computing trust income is properly applied to qualified funeral trusts, and to advocate the exemption of cemetery maintenance trusts from the new tax. To learn more about the tax, click here.
ICCFA Files "Friend of Court" Brief in Landmark Litigation in PA (February 2013)
Last Friday, the ICCFA filed the an Amicus Curiae ("Friend of the Court") brief with the U.S. Court of Appeals for the Third Circuit in Heffner, at al. v Murphy, et al. This landmark decision by the lower federal district court found eleven provisions of the Pennsylvania Funeral Directors Law unconstitutional. Should the appeals court affirm the district court opinion, this ruling will directly affect state funeral boards within the Third Judicial Circuit, that is, Pennsylvania, New Jersey and Delaware. Also, as the leading case law on this issue, the Heffner ruling would be the leading decision in all the other judicial circuits in the United States.
The lower court’s ruling invalidates sections of the state funeral law that, among others, requires a prep room in each establishment, restricts food service at funeral homes, and the use of trade names, prohibits the payment of commissions, and allows relatives who are not licensed funeral directors to inherit ownership while prohibiting other licensed entities from such ownership. The ICCFA brief focuses on state funeral laws in general and the Pennsylvania law in particular, noting that such legislation has served to legalize decades of protectionist, anti-competitive practices. The ICCFA brief may be viewed by clicking here.
ICCFA responds after previewing the CNBC program, "Death: It's a Living" (January 2013)
The ICCFA obtained a DVD of the program from CNBC that is labeled "rough cut," meaning that it may be revised prior to broadcast. But assuming that the show basically airs as is, funeral professionals may be pleasantly surprised to find a reasonably balanced presentation that is actually encouraging to consumers. Read more
Thoughts on Money Magazine's Series "The High Cost of Saying Goodbye" (November 2012)
I’ve learned to detect a media hit job on the funeral profession whenever I see a reference to Jessica Mitford’s book, The American Way of Death. Now look, what are the chances that the journalists in question have ever cracked open a copy of this half-century old book, written before many of them were born? I guess that the purpose in citing this book is to “prove” that problems with funeral homes aren’t new. OK, but my problem with the reporters is that they haven’t bothered to find out exactly what problems are in the book. They’d be surprised if they did. Read more
ICCFA responds to the 60 Minutes segement "Final Resting Places" (May 2012)
The ICCFA understands that a 12-minute television segment does not permit much detail or nuances. However, since 60 Minutes chose to relate the atrocities that occurred at Burr Oak Cemetery in 2009, we believe that it had a journalistic responsibility to also report that the cemetery staff involved were prosecuted and are now serving prison terms. No mention was made of this. Read more
Rep. Bobby Rush has reintroduced his bill, the Bereaved Consumers Bill of Rights Act, into the House of Representatives. The bill, H.R. 900, appears to be identical to last year's bill, formerly H.R. 3655, including the limited exemption for religious organizations that are not affiliated with a for-profit entity. Contrary to speculation in some quarters of the funeral industry, this bill would affect funeral homes as well as cemeteries, crematories, and related businesses. Also, the bill does not restrict the Federal Trade Commission in its mandate to establish a "Funeral Rule II," but lists a number of components at a minimum that should be in the new regulation. It is unclear how far-reaching the trade regulation could be if enacted into law, but it is a near certainty that industry groups currently supporting the legislation would be significantly impacted. To view H.R. 900, go to http://www.iccfa.com/files/HR 900 Bereaved Consumers Bill 2011.doc.
CALL TO ACTION regarding H.R. 3655 - December 9, 2010
ICCFA Contacts State Associations Concerning H.R. 3655, Bereaved Consumers Bill of Rights Act. Last week, the ICCFA send a memo to all of the state funeral directors associations containing a blunt assessment of the likely impact of H.R. 3655, the Bereaved Consumers Bill of Rights Act, should it become law. The legislation is now pending action in the full Energy and Commerce Committee prior to being sent to floor of the House of Representatives for a vote. A similar memo, which has also been sent to the state cemetery associations, was authored by Government and Legal Affairs Chairman Irwin W. Shipper, CCE.
In part, the memo states, “I am taking this unusual step of contacting you directly because we are facing a most unusual bill in the Congress of the Unites States that could change the way we do business and literally put many of us out of business. I am referring to H.R. 3655, the Bereaved Consumers Bill of Rights Act, introduced by Rep. Bobby Rush (D-IL) and recently reported favorably out of his subcommittee of the House Energy and Commerce Committee. So this legislation is on the move!
“H.R. 3655 requires the Federal Trade Commission to establish a “Funeral Rule II” covering all sellers of funeral goods or services, including nonprofit, religious and municipal entities. Even funeral providers currently under the existing Funeral Rule – i.e., funeral homes - would be saddled with new disclosure requirements under this legislation so nobody gets a free ride. However, we are concerned that some of the state funeral directors associations, and the National Funeral Directors Association, have been lobbying in support of this legislation. Unless we’re missing something, we believe this advocacy in favor of H.R. 3655 by members of our profession is counterproductive and very harmful. Here’s why:
“We are all consumers and everybody is in favor of consumer protection. That said, we are convinced that H.R. 3655 is a bad bill that would make bad law, then open the floodgates to amendments and expansion in the years ahead.
“Stop for just a minute and estimate the costs to your business should H.R. 3655 become law and the FTC regulates, or in the case of funeral homes, increases the regulation of your business. Add the risk of astronomical fines and the effect all this will have on your bottom line.
“I think you will agree that we must do everything possible to stop H.R. 3655 from becoming law. There are two ways you can help: First, as a state association, please contact the members of your state Congressional delegation by phone or e-mail and tell them that a.) H.R. 3655 is a highly controversial bill within our profession; and b.) you believe the legislation if enacted will cause substantial harm to our businesses with little or no commensurate benefit in consumer protection. Second, please urge your members to contact their respective members of Congress by phone or email with the same two points.”
The ICCFA memo concluded by observing, “The time to discover that H.R. 3655 is harmful to your business is NOT after it has been enacted into law. Please take action now. Thank you.” A copy of the memo can be viewed on the ICCFA Web site at https://www.iccfa.com/files/HR3655StateFuneralAssnMemo.pdf.
On The Move: H.R. 3655, "Bereaved Consumers Bill of Rights Act," Favorably Voted Out of Subcommittee. On March 24, the House Energy and Commerce Subcommittee on Consumer Protection, chaired by Rep. Bobby Rush (D-IL,) held a markup session on several bills including H.R. 3655, the Bereaved Consumers Bill of Rights Act. This bill would require the Federal Trade Commission to establish a “Funeral Rule II” covering all sellers of funeral goods or services including cemeteries, crematories, and monument retailers. Religious and municipal entities would also be covered. To nobody’s surprise, the chairman’s bill was favorably reported out of the chairman’s subcommittee (by simple voice vote) to the full Energy and Commerce Committee. However, two amendments to the bill were proposed – one by Rep. Rush himself, the second by Rep. Joe Barton (R-TX). Again to nobody’s surprise, the chairman’s amendments were adopted, while the Republican’s amendments were rejected.
The added language in the Rush amendment requires a higher standard for the mandatory disclosures. Merely “disclosing” certain information has been elevated to disclosing “clearly and conspicuously,” thus creating a subjective standard that may be disputed by enforcement actions. The defeated Barton amendment called for the FTC to study the incidents of deceptive or abusive practices in the industry and report its findings to Congress. However, the FTC has already reported that out of some 1.3 million complaints filed by consumers during 2009, only 242 complaints were funeral-related. That amounts to 0.02% (of one percent). Please see the next story for more information.
Recently, NFDA announced that it was lobbying “strongly in support” of H.R. 3655 although, ironically, it does not represent the segments of funeral and cemetery industries that would be the most affected should the legislation become law. However, funeral homes would also face additional potential liabilities for new contract disclosures under H.R. 3655 with smaller businesses more heavily impacted by the $16,000 fines per violations. The ICCFA opposes the bill because it seeks to establish a minefield of violations based on relatively minor offenses or omissions, punishable by crushing fines. ICCFA members are urged to call or email their members of Congress to express their concerns with H.R. 3655. The ICCFA Speaking Points on H.R. 3655 can be viewed at http://www.iccfa.com/files/HR3655speakingpoints.pdf.
U.S. Dept. of Commerce Seeks ICCFA Feedback on 2012 Economic Census Form. The ICCFA has been contacted by the U.S. Department of Commerce concerning the planned 2012 economic census forms. In particular, Commerce wants to know our members' data needs and reporting problems in the census. The previous 2007 economic census provides useful data although the information appears incomplete. The Census or NAICS Code for "Death Care Services" is 8122, and is subdivided into 81221 for "Funeral Homes and Funeral Services" and 81222 for "Cemeteries and Crematories."
According to the 2007 economic census data, there are a total of 21,313 death care services establishments in the U.S., having revenue of $15.3 Billion, and an annual payroll of $4.2 Billion. Funeral homes account for 15,634 of the total number, $11.9 Billion in revenue, and an annual payroll of $3.0 Billion. The number of cemeteries and crematories in the U.S. is listed at 5,679 establishments, with $3.3 Billion in revenue and $1.1 Billion annual payroll. In both cases of funeral homes and cemeteries/crematories, the number of establishments seems low.
Industry census data can be viewed at www.census.gov and selecting "American Fact Finder." Funeral homes, cemeteries and crematories are listed under category 81, "Other Services (Except Public Administration)." Any comments for the Department of Commerce concerning the 2012 economic census should be forwarded to ICCFA general counsel Bob Fells at firstname.lastname@example.org or cal 1-800-645-7700.
ICCFA Testifies on H.R. 3655: Seeking to Create "Funeral Rule II;" Bill Would Impose Excessive Penalties for Minor Omissions. Last week, the ICCFA testified before the U.S. House Energy and Commerce Subcommittee on Consumer Protection concerning H.R. 3655, the Bereaved Consumers Bill of Rights Act. The Subcommittee Chair is also the sponsor of the bill, Rep. Bobby Rush (D-IL), who introduced H.R. 3655 in response to the Burr Oak Cemetery investigation in his Congressional district. According to reports, human remains at Burr Oak were illegally disinterred and mishandled, and the graves fraudulently resold. However, the ICCFA expressed its concern that H.R. 3655 addresses none of these issues but instead requires the Federal Trade Commission to initiate a new "Funeral Rule II" covering all sellers of funeral goods or services, including nonprofit and religious cemeteries.
The ICCFA was represented at the hearing by Past President Paul M. Elvig who complimented Chairman Rush on his leadership regarding the issues and urged that the bill be amended to make illegal disinterments a federal crime punishable as a felony. Elvig stated that the ICCFA supports "the concepts and disclosures contained in Section 3 of H. R. 3655 as good business practices" and "reflect the very same standards contained in the ICCFA Model Guidelines published over a decade ago" and accessed on the Association's Web site.
The centerpiece of the bill would require the FTC to enact a new trade rule requiring various consumer disclosures by any business selling any type of funeral merchandise or services. "Typically, under an FTC trade rule, we understand that violations are statutorily imposed at the rate of $11,000 per violation," Elvig stated. "Frankly, this amount could bankrupt a number of smaller cemeteries that operate with volunteer staffs and possibly one or two paid employees." In the alternative, ICCFA suggested the development of FTC "Funeral Guides" enforced by Section 5 of the FTC Act. "The advantage of this approach would also track patterns of misconduct by a business as determined by the Guides, rather than imposing fines for isolated, one-event 'gotcha' shortcomings that are sometimes the approach to trade rule enforcement. In its present form, H.R. 3655 would impose excessive penalties for some relatively minor omissions of disclosure in a manner suggesting that the punishment outweighs the offense."
The ICCFA also expressed its concerns with the bill's coverage of nonprofit entities including religious organizations that raises both constitutional and jurisdictional issues. For example, the FTC's jurisdiction is generally limited to for-profit businesses although the witness for FTC affirmed that the Commission could bring enforcement actions against municipal cemeteries. Elvig stated that ICCFA "believes that cemeteries and funeral homes are most efficiently and effectively regulated at the state level. These entities operate locally in their communities and therefore it makes sense to hold them accountable locally. Elvig also noted that state authorities in Illinois swiftly investigated the Burr Oak scandal and enacted new legislation. "We think it fair to ask what role, if any, the federal government could have or should have played when state and local authorities had the situation well in hand."
Also testifying at the hearing were witnesses representing the FTC, NFDA and the Illinois Cemetery Task Force. The written testimonies and a video of the hearing itself can be viewed at the Subcommittee Web site at http://bit.ly/9cUUEk. [PLEASE NOTE: when viewing the video, fast forward to the 18:00 minute mark on the timer for the beginning of the hearing; the ICCFA testimony begins just after the 50:00 minute mark.]
FTC Funeral Consumer Complaints Sought by ICCFA for Analysis. The ICCFA has submitted a FOIA (Freedom of Information Act) request with the Federal Trade Commission to obtain copies of consumer complaints filed with the FTC during 2008 concerning funeral-related businesses. In the past, the ICCFA's review of FTC consumer complaints has enabled the Association to document the volume and types of problems that consumers may be experiencing with funeral homes, cemeteries, and related entities. Historically, the number of complaints have been low and mainly limited to alleged violations of the Funeral Rule. The purpose of the FOIA review is to enable the Association to determine whether the number or types of complaints have changed. The final tally is reported to ICCFA members and shared with the FTC staff.
Congressional Networking Survey Conducted by ICCFA. All ICCFA members should check their mail for the biennial Congressional and Federal Networking Communications survey. The purpose of the survey is to identify ICCFA members who know members or staff of Congress or staffers in the various federal agencies. There are many first-time members of the new 111th Congress, which creates an excellent opportunity to become acquainted with your Congressional representatives, especially if you have not done so in the past. The information provided by members will be kept confidential and used only when an issue requires ICCFA to contact Congressional representatives and senators. All ICCFA members are urged to complete the survey and return it to Association HQ in the return mailer provided. For assistance in contacting your Congressional delegation, please call ICCFA general counsel Bob Fells at 1-800-645-7700.
In case you missed the Employee Free Choice Act (EFCA) webinar by ICCFA labor counsel Mike Pepperman, you can now watch the replay on a free compact disc. The EFCA is proposed federal legislation seeking to increase labor union membership by depriving workers of the right to vote by secret ballot when deciding to accept or reject union representation, among other things. It is widely believed that the bill will be enacted into law at some point this year. The webinar reviews the provisions of the legislation and how members can develop strategies in dealing with it. ICCFA members wanting to order their free CD of the ECFA webinar should call ICCFA general counsel Bob Fells at 1-800-645-7700.
The ICCFA announced that it has retained the services of veteran fraud investigator Robert A. Garvey Jr., CPA, CFE, CrFA, CVA, to serve as a consultative resource for members' employee theft and fraud concerns. The new member benefit, the "Fraud Investigation and Deterrence Consultation Service" or FIDCS, will allow members to discuss by telephone any issues or concerns related to suspected fraudulent activity or a desire to put systems and controls in place at their locations to deter such activity. There is no cost to ICCFA members in good standing to utilize this benefit. The number to call is 1.866.649.1902.
ICCFA President Mark J. Krause, CFuE, announced the new service saying, "Unfortunately, in today's economy, all businesses are concerned about a potential increase in employee theft, and our association felt that it was important to be proactive in providing a service to help deter this type of misconduct and handle situations properly if fraud is suspected. The association has worked with Mr. Garvey and his firm, McLean, Koehler, Sparks & Hammond, for a number of years and we are confident that our members will find his knowledge and experience very beneficial to their circumstances. This new benefit is another example of the expanding services that the ICCFA is providing our members."
In response to the November elections, the conventional wisdom in Washington, DC, predicts the enactment of the Employee Free Choice Act (EFCA) early in 2009. This legislation will help labor unions increase their membership by eliminating the secret ballot safeguard by which employees may decide whether or not to unionize. The ICCFA has opposed enactment of this bill, but support/opposition in Congress has divided along party lines—Democrats for it, Republicans against it. Given the increased Democratic majorities in both the House and Senate, and a new Democratic President, passage of EFCA is generally viewed as nearly a sure thing.
However, the ICCFA is providing its members with an EFCA "toolbox" containing strategies for employers to help their workers evaluate organizing efforts and employment benefits under the anticipated legislation. It is important for employers to recognize that their responses will become limited by law once a union organizing effort is underway in their workplace. The EFCA toolbox has been developed by ICCFA labor law counsel Michael Pepperman, Esq., and can be accessed below.
The so-called "Red Flag" regulations under the Fair and Accurate Credit Transactions Act of 2003 (FACTA), are effective on November 1, 2008, and mandatory for financial institutions and also for creditors. As defined under the regulations, the term "creditors" may include businesses such as funeral homes or cemeteries.
The regulations require covered businesses to develop and implement a written identity theft prevention program for the identification, detection, and response to patterns, practices, or specific activities (known as "red flags") that could indicate identity theft. Cemeteries or funeral homes that help customers arrange for credit, arrange for customers to pay in multiple installments or multiple insurance premiums may be considered "creditors" under the regulations.
According to the Federal Trade Commission, "A creditor is any entity that regularly extends, renews, or continues credit; any entity that regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who is involved in the decision to extend, renew, or continue credit. Accepting credit cards as a form of payment does not in and of itself make an entity a creditor. Creditors include finance companies, automobile dealers, mortgage brokers, utility companies, and telecommunications companies. Where non-profit and government entities defer payment for goods and services, they too, are to be considered creditors." The ICCFA sample Identity Theft Prevention Program can be accessed by members here.
ICCFA Offers Funeral Rule GPL Compliance Review Check for Members. President Mark Krause has announced a new exclusive benefit for all ICCFA members in good standing. Effective immediately, members whose businesses must comply with the FTC Funeral Rule's General Price List (GPL) requirements can have their lists reviewed by attorney Poul H. Lemasters, Esq., without charge. The ICCFA has retained the services of Mr. Lemasters, who is an attorney and a licensed funeral director, to provide telephone consultation on cremated-related legal issues. Now this service has been expanded to include GPL reviews. Poul Lemasters of the firm Rosenacker & Associates, Ltd., Cincinnati, Ohio, can be reached at 1.800.221.2889.
New workplace legal requirements are already on the way since President Bush signed into law last month the ADA Amendments Act of 2008 that significantly modifies the original Americans with Disabilities Act signed into law by the President's father, George H.W. Bush, in 1990. The new provisions expressly overturn several landmark U.S. Supreme Court decisions that narrowly interpreted the definition of "disability" and will make disposing of ADA cases prior to trial more difficult for employers. The new law is effective on January 1, 2009.
Among the many provisions, the new law states that the existing definition of a "disability" now "shall be construed in favor of broad coverage of individuals... to the maximum extent permitted by the terms of [the ADA]." The new law "lowers the standard to prove an employer discriminated against an individual whom it 'regarded ad' having a disability. However, such "regarded as" claims cannot be based on "transitory and minor impairments where the impairment is expected to last less than six months. Also, employers are not required to provide a reasonable accommodation to individuals who are regarded as disabled, an issue over which the federal courts were previously split."
It is recommended that employers take the time now to review existing procedures for ADA compliance at "every stage including hiring, medical testing, accommodation, leave and determination." Job descriptions should also be reviewed because they are often a starting point for an individualized assessment. For more information on the new ADA amendments, you may read the PDF document below check the Web site of the law firm Jackson Lewis at www.jacksonlewis.com/legalupdates/article.cfm?aid=1507.
The U.S. Department of Labor recently published new final regulations for the Family and Medical Leave Act (FMLA) that are the first significant changes since 1993. Employers must revise their employee handbooks and train human resources personnel concerning the new rules to ensure compliance. The new rules also implement provisions in the National Defense Authorization Act affecting leave entitlements under FMLA. The ICCFA can help you with compliance, so see the PDF document below for more information.
New Whistleblower Protection and Document Retention Policies Mandated by Federal Govt; Sample Compliance Language Provided by ICCFA
The ICCFA has published an informational alert to government entities and to the private sector in the current edition of The Critical Infrastructure Protection (CIP) Report, published by George Mason University School of Law as part of the ongoing efforts to prepare the nation for catastrophes, either natural (hurricanes, pandemics) or man-made (terrorism). This monthly report is widely circulated throughout academia, the private sector, federal and state government agencies, and Congress.
The article, "Mass Fatalities Management in the Context of Disaster Planning," focuses on the work of the Mass Fatalities Management (MFM) Services Sub-Council, which functions in conjunction with the Departments of Homeland Security, and Health and Human Services. An ongoing challenge for the Sub-Council is to convince other stakeholders, including government agencies and other private sector groups such as transportation, energy, chemical, even banking and finance, that they will be affected by MFM -- or the lack thereof. Therefore, it has become crucial to raise the awareness level of other stakeholders to participate and coordinate their emergency responses to include MFM needs. The article was authored by ICCFA general counsel Bob Fells, who serves as co-chair of the MFM Sub-Council. Anyone interested in obtaining more info about CIP or in subscribing to the Report (IT'S FREE!), should go to http://cipp.gmu.edu.
ICCFA participated in an economic briefing convened by the White House regarding the expiring "Bush tax cuts" that lowered tax rates beginning in 2001 and 2003. The cuts included repeal of the estate or "death" tax from 55 percent to zero. These rate reductions will expire at the end of 2010, including restoration of the estate tax, unless Congress approves an extension or makes the tax cuts permanent. The ICCFA was represented by Bob Fells, external chief operating officer and general counsel. Near the conclusion of the briefing, President Bush unexpectedly joined the meeting and discussed the importance of maintaining the tax rate reductions.
Among the financial data presented, the following highlight some areas of concern. If the 2001 and 2003 tax cuts expire in 2010:
-- 27 million small business owners will face an average tax increase of $4,066;
-- 18 million seniors will face an average tax increase of $2,181;
-- 12 million single women with dependents will face an average tax increase of $1,091;
-- 48 million married couples will face an average tax increase of $3,007, due in part to the restoration of the "marriage penalty" tax;
-- A family of four earning $50,000 will face a tax increase of over $2,100, or a 191 percent increase.
The briefing was convened by the Council of Economic Advisors and the National Economic Council, which limited invitations to approximately 150 members of the Coalition for Tax Reform.
ICCFA co-chaired a Mass Fatalities Management meeting in Washington, DC. The U.S. Department of Homeland Security convened a workshop conference in Washington to discuss with private sector representatives in the death care industry various initiatives to ensure adequate planning for mass fatalities and community needs. Discussions focused on methods to alert other sectors to the need to coordinate and prioritize services including transportation, energy, chemical, banking and financial, and communications, among other industries. The ICCFA was represented by general counsel Bob Fells; other organizations represented were CANA, NFDA, the National Funeral Directors and Morticians Association, the Casket and Funeral Supply Association, and the Dodge Company.
The main focus of the planning sessions that the ICCFA has participated in over the past two years is how to protect operations in the 18 sectors that comprise the "critical infrastructure and key resources" (CIKR). There was a consensus among the group at the June 13 meeting that in the first 24 to 72 hours following a disaster, whether caused by a flu pandemic, natural catastrophe or terrorist attack, localities would be on their own to cope with the consequences and that federal agencies could not be viewed as the "cavalry" coming to the rescue. Losses to the workforce are generally estimated at between 25 and 40 percent, either as casualties or as caregivers, and emergency business plans should be developed by all companies in order to remain operational for CIKR purposes. The group is currently drafting sector-specific issues and needs for distribution to sectors having an impact on mass fatalities management.
FTC Announces Closing of Funeral Rule Regulatory Review. As the only trade association in the industry that advocated against expanding the FTC Funeral Rule to include cemeteries, the ICCFA was pleased to see this 10-year review proceeding come to a close with no expansion of the rule.
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