In September we posted about a regulation proposal that sought to define the role of a sub-committee of the Missouri State Board of Embalmers and Funeral Directors (Missouri’s Financial Examination Committee: What Role?). While the Board eventually gave its staff instructions to revise that proposal, the regulation has yet to resurface. Instead, the Staff Recommendations include suggested actions that the Examination Committee may take.
The Recommendations contemplate that a seller could submit to the Examination Committee a plan to resolve cited exceptions over a period of up to 18 months. Or that the Examination Committee could offer direction to the seller on how to resolve the exceptions over a period of up to 18 months, unless special circumstances exist. All at the Examination Committee’s discretion. The concern that some industry members raised in September was that the Examination Committee had too much discretion, and that sellers were being pressured into resolutions that were not required by law. The Recommendations would have the State Board delegate authority to the Examination Committee the authority to define compliance requirements to preneed sellers.