The staff for the Missouri State Board of Embalmers and Funeral Directors released the revised preneed renewal reports this week, and those revisions include a few new additional requirements. Those requirements include a seller providing a ‘no tax due’ letter, proof of corporate status and any ‘doing business as’ filings. However, the new requirement that will catch most funeral directors by surprise will be the new Section Q: preneed contracts funded by insurance assignments.
Section Q seeks from the preneed seller information about each insurance assignment taken to fund a preneed contract. Funeral directors will find the instructions somewhat confusing. Those instructions advise that a report is to be prepared for each insurance company, but the spreadsheet format incorporated into the report suggests each column could be for a different insurance company. The seller is also instructed to mark the spreadsheet with 'NA' if the section does not apply. With the form instructions alluding to preneed contracts “sold” pursuant to Sections 436.400-436525 RSMo., most funeral homes will assume the assignment of an existing insurance policy is not covered by Chapter 436. The instructions do not address policy beneficiary designations.
The staff scheduled an August 21st State Board meeting that includes “renewal update” on the agenda. With the renewal forms having only been published on August 17th, the staff hasn’t given the industry adequate time to provide input at the August 21st meeting. This should make for an interesting September State Board meeting, and for October chaos for Missouri’s preneed sellers (and those funeral homes dependent upon third party sellers).