What the FTC Funeral Rule Requires at Each Point of Contact

The three price lists and when each one must appear

The FTC Funeral Rule requires funeral homes to use and distribute three core price lists: the General Price List (GPL), the Casket Price List (CPL), and the Outer Burial Container Price List (OBCPL). Each has its own timing and purpose. Understanding exactly when to present each one is essential for compliance and for avoiding misunderstandings during arrangements.

The GPL is the centerpiece. It must be offered at the start of any in-person discussion about prices, funeral goods, or services. The CPL and OBCPL come into play when a family expresses interest in caskets or outer burial containers, typically during the arrangement conference or at the display room.

Each list must be physically presented at the right moment, not simply made available. Copies must be clear, up to date, and easily readable. Electronic presentation is permitted if the arrangement is handled remotely, but the timing and completeness rules still apply.

Keep reading: How to Arrange a Veteran Burial: Eligibility, Forms, Markers

Telephone price disclosure and what you must answer

The Funeral Rule treats phone calls differently from in-person visits. If a caller asks about prices or offerings, staff must provide accurate information over the phone. There is no requirement to mail or email a price list following a call, unless the caller requests it.

It is not enough to say "come in and we'll discuss." Staff must answer any direct questions about offerings and their prices. This includes basic service fees, costs for specific packages, and prices for individual goods such as caskets or cremation containers.

Staff training and scripts

Directors should ensure that anyone who answers the phone knows the basics of the GPL. Many homes use a summary sheet or script to help staff answer confidently and avoid guesswork. The Funeral Rule does not require you to quote every single item, but if a caller asks about a particular service or product, you must provide the price.

Documenting the call is not required by the Rule, but some operators keep brief notes as a best practice, especially if the call leads to a follow-up meeting or arrangement.

Handing over the General Price List before arrangements are discussed

For every in-person meeting about funeral arrangements, the GPL must be provided before discussing specific goods, services, or prices. This applies whether the meeting takes place at the funeral home, at the family's residence, or elsewhere.

The GPL must be a physical printed document, unless the meeting is virtual, in which case an electronic version is acceptable. The Rule is explicit: handing over the GPL must occur before any meaningful discussion about arrangements. If you begin talking about packages, casket choices, or service fees before presenting the GPL, you are out of compliance.

What the GPL must include

The GPL must list all goods and services you offer, whether sold separately or as part of packages. It must include identifying information for your funeral home, the effective date, and clear descriptions of each item. Required wording about embalming and other legal disclosures must appear on the GPL as well.

Many homes distribute the GPL even if the conversation turns out to be brief or informal. The safest policy is to err on the side of providing the GPL early and documenting that you did so, especially if the discussion proceeds to specifics.

Keep reading: Trust Funded vs Insurance Funded Preneed: How Each Pays Out

Casket and outer burial container price lists at the display

When families are shown caskets or outer burial containers, the CPL and OBCPL must be physically provided at the start of the viewing. These price lists must include all items regularly offered, along with a brief description and the current retail price for each.

The price lists can be separate sheets or a combined document, as long as they are clearly organized. Photographs and product codes are optional but can help avoid confusion, especially if several similar models are available.

Handling non-traditional or custom items

If you offer caskets or containers that are not on the regular floor display, those items must still appear on the price lists. For custom items, the Rule expects you to list a price range or starting price, and to make pricing clear if a family expresses interest. If an outside vendor is involved, you must disclose any additional handling fees.

It's not necessary to hand over the CPL or OBCPL if the family does not wish to view caskets or containers at all. However, if the conversation turns to those goods, you must provide the relevant list before the family is shown the merchandise or provided detailed information.

The itemized statement of goods and services selected

Once the family has made selections, the Funeral Rule requires you to prepare a written, itemized statement listing all goods and services chosen, along with the specific prices for each. This statement must be given to the person making arrangements at the conclusion of the arrangement conference, and before the contract is finalized or any payment is received.

The statement must list each item separately, with a corresponding price. Package deals can be shown, but the statement must also break out each component if the family requests. Subtotals for major sections, such as professional services, merchandise, and cash advances, help families see where costs are concentrated.

Required signature and timing

There is no requirement for the family to sign the statement, but many funeral homes do so for documentation. The key is timing: the family must receive the statement before they pay or sign any contract. This allows them to review and ask questions, ensuring transparency and giving them a chance to change selections if needed.

If the arrangement is handled over the phone or electronically, the statement can be sent via email or another agreed-upon method, but a copy must be received by the family before payment.

See how RemembranceDesk handles this for funeral services

Embalming, cash advances, and the required written disclosures

The Funeral Rule targets several common miscommunications with required written disclosures on the GPL and the final statement. Embalming, in particular, is an area of scrutiny.

Embalming: explaining when it is and is not required

The GPL must state that, except in certain special cases, embalming is not required by law, and alternatives such as refrigeration are available. If embalming is required due to specific circumstances, you must explain the reason. Charging for embalming without permission, or implying that it is always required, is a violation.

Cash advances: identifying and disclosing outside charges

Cash advance items are goods or services that you pay for on the family's behalf, such as cemetery fees, flowers, clergy honoraria, or newspaper notices. The statement must identify each cash advance item, and if you mark up these charges or receive a commission, you must disclose this in writing. The intent is to prevent families from being surprised by additional costs that originate outside your firm.

These disclosures must be clearly worded and prominent on both the GPL and the itemized statement. Boilerplate language is acceptable, but it must be accurate and specific to your offerings and local requirements.

How long price lists and statements must be retained

The Funeral Rule requires funeral homes to keep copies of the GPL, CPL, OBCPL, and each itemized statement of goods and services selected for at least one year from the date they were last distributed or used. Best practice in the industry is to retain these documents for a longer period, often three to five years, both for internal review and in case of an FTC inspection or consumer complaint.

Retention can be physical or electronic, provided the documents are easily retrievable and complete. For electronic records, make sure files are backed up and the format remains readable as technology changes. If you revise your GPL or other lists during the year, keep each version along with a note indicating the dates in use. This helps clarify which price list was provided to each family should questions arise later.

For multi-location operators, ensure that each site maintains its own records. Centralized digital systems can help keep everything organized, especially if you update price lists seasonally or in response to supplier changes. Remember, the FTC looks for documentation that matches what was handed to the family and what was in effect at the time of the arrangement.

Staying compliant with the Funeral Rule's documentation requirements can be demanding, especially for small, family-run homes where paperwork competes with daily work. Digital tools that automatically generate, store, and retrieve price lists and statements can simplify compliance. Systems that publish obituary and service information pages with galleries, times, and condolence collection often have these features built in, reducing the risk of missing a required disclosure or losing track of a vital record.