For nine posts, we've tried to be analysts. We've documented what the Funeral Rule requires, what it doesn't, and where the gaps are. We've cited federal sources, let the data speak, and resisted the temptation to tell you what to think.
This post is different. This is our perspective.
We're not lobbyists. We're not a trade association. We're not a consumer advocacy group. We're a small funeral service in Denton, Texas, founded by a licensed funeral director who has sat on both sides of the arrangement table and built a business in the space the Rule left behind.
If the FTC asked us what the Rule should become, here's what we'd say.
1. Require Online Price Posting
This should have happened a decade ago. It should happen now.
Every funeral provider with a website should be required to post their General Price List on that website, in a format that consumers can access without creating an account, submitting a request, or providing personal information. The GPL should be downloadable, printable, and machine-readable.
The arguments against this are familiar. Pricing is complex. Families might make decisions without context. Small providers face a compliance burden. We've heard these arguments in every review cycle since 2019, and we find them unpersuasive.
Pricing is complex in healthcare, too. Hospitals are now required to post their standard charges online. Pricing is complex in legal services, in home renovation, in auto repair. Every industry that has moved toward online pricing transparency has discovered that consumers are capable of processing complex information when it's presented clearly.
The compliance burden argument is particularly thin. If a funeral home has a website, adding a PDF of its GPL is not a significant technical challenge. If a funeral home does not have a website, the requirement wouldn't apply. The providers who are most burdened by this proposal are the ones who have chosen not to post prices, not the ones who lack the ability.
The families who need this most are the ones who are least equipped to advocate for themselves: the grieving, the overwhelmed, the families who live far from the funeral home, the families who are comparison-shopping under time pressure. Requiring them to call, wait, parse verbal information, and compile it manually is not consumer protection. It is an obstacle course dressed as a process.
Post the prices. Let families see them. Trust consumers with information.
2. Extend the Rule to Cover Cemeteries
Cemeteries that sell goods and services to the public should be subject to the same disclosure requirements as funeral homes. The current exemption for most cemeteries creates a regulatory gap that families fall through at the most vulnerable point in the process.
A family that has just navigated the funeral home's GPL, made informed choices about caskets and services, and exercised their right to unbundle may then walk into a cemetery transaction where none of those protections exist. No itemized price list. No unbundling requirement. No prohibition on tying. No third-party purchase protections.
The argument that cemeteries are different from funeral homes is a regulatory distinction that means nothing to the family writing the check. They are buying goods and services related to the final disposition of a loved one. The consumer protection rationale is identical.
3. Address the Cremation Majority
The Funeral Rule was written when fewer than 15% of American families chose cremation. Today, more than 60% do. The Rule's structure, its definitions, its disclosure requirements, and its price list formats should reflect this reality.
At a minimum, the Rule should require clearer disclosure of direct cremation pricing, including a standardized format that makes comparison across providers straightforward. The current requirement to list direct cremation at three price points (provider casket, alternative container, customer-provided container) is sound in principle but invites the kind of advertising ambiguity we described in Part 5. A standard format, consistently applied, would close that gap.
More broadly, the Rule should acknowledge that for the majority of American families, the funeral home is no longer the sole or even primary point of contact. Families use cremation societies, direct cremation providers, online arrangement platforms, and a growing number of non-traditional services. The Rule's definition of "funeral provider" should be examined to ensure that all entities selling cremation goods and services to the public are covered.
4. Create a Post-Disposition Consumer Framework
This is the gap we see every day.
After the funeral or cremation is complete, families face decisions about permanent placement, memorialization, scattering, and long-term care of cremated remains. These decisions involve real costs, real complexity, and real emotional weight. And there is no consumer protection framework governing them.
We are not suggesting that the FTC regulate every conversation a family has after a cremation. But we are suggesting that the principle underlying the Funeral Rule, that families making consequential decisions under emotional duress deserve transparent pricing and honest information, does not stop applying when the urn comes home.
A starting point would be requiring any entity that sells placement, scattering, or memorialization services to provide a written price list and to disclose the scope and limitations of its services before the family commits. This would be a modest extension of the GPL principle into a market that currently operates with no standardized disclosure at all.
5. Standardize GPL Format for Readability
The Rule specifies what must be on the GPL. It does not specify how that information must be organized, formatted, or presented. The result is that two GPLs from two providers may contain the same required information and be nearly impossible to compare side by side.
A standardized GPL template, similar in concept to the Nutrition Facts label on food packaging, would allow families to compare providers as easily as they compare products in a grocery store. The required information is already defined. The missing piece is a common format.
This is not a radical proposal. The ANPR asked about GPL readability. Consumer groups have advocated for standardization. A standard format would benefit ethical providers by making their competitive pricing visible and would benefit families by reducing the cognitive burden of comparison at a moment when cognitive resources are scarce.
6. Recognize New Forms of Disposition
Alkaline hydrolysis, natural organic reduction, conservation burial, and other emerging methods are legal in a growing number of states. The Rule should be updated to include these methods in its definitions, disclosure requirements, and price list structures.
Families choosing these options deserve the same protections as families choosing burial or cremation: itemized pricing, informed consent, and the right to choose only the goods and services they want. The Rule's silence on these methods creates a regulatory vacuum that will only widen as adoption grows.
7. Require Multilingual GPL Availability
In communities where a significant portion of the population speaks a language other than English, funeral providers should be required to make the GPL available in the predominant languages of their service area. The ANPR asked about this. The answer should be yes.
The Funeral Rule's core premise is that families need clear information to make informed decisions. A GPL in a language the family cannot read is not clear information. It is a formality.
8. Strengthen Enforcement
The FTC has inspected roughly 2,900 funeral homes over nearly 30 years. There are approximately 19,000 funeral homes in the United States. The math speaks for itself.
Enforcement doesn't require new rulemaking. It requires resources and priority. More frequent test-shopping sweeps, meaningful penalties for non-compliance, and public reporting of enforcement outcomes would do more to protect consumers than any single regulatory change. The Rule that exists is a good rule. It needs to be enforced as if it matters.
What We're Not Saying
We're not saying the funeral industry is full of bad actors. It isn't. The vast majority of funeral professionals are honest, compassionate people who entered this profession because they believe in serving families at the worst moments of their lives.
We're not saying the Funeral Rule has failed. It hasn't. The protections it established in 1984 were groundbreaking, and they continue to serve families who know how to use them.
We're not saying regulation is the only answer. It isn't. The market is already moving toward transparency. Providers who lead on price posting, clear communication, and consumer education are gaining competitive advantage. The best funeral homes in America are already doing most of what we've described, not because a regulation requires it, but because it's the right way to serve families.
What we are saying is this: a consumer protection regulation that hasn't been substantively updated in over 30 years, that doesn't cover the majority of disposition choices, that doesn't require online pricing, and that is enforced at a pace of once per century per funeral home, is a regulation that has fallen behind the people it was meant to protect.
The families are still vulnerable. The decisions are still consequential. The information asymmetry is still real. The Rule was built to address all of those things. It should be updated to address them in 2026.
Thank You
This series was written for families who deserve better information and for funeral professionals who believe transparency makes the industry stronger. If you've read all ten parts, thank you. If you've shared any of them, thank you more.
The Funeral Rule isn't a topic most people think about until they need it. By then, it's too late to learn what it says. We wrote this so it wouldn't have to be.
If you have cremated remains at home and you're wondering what comes next, that's what Bespoke Undertakings does. No pressure, no timeline. Just help, when you're ready.