In our January 3rd Post, we described the process (or lack of process) between the State Board of Embalmers and Funeral Directors and the Division staff for establishing the examination procedures that would be applied to preneed sellers for the next five years.  The industry railed at the Staff’s recommendations for the scope of financial examinations and the sellers’ recording keeping requirements, and the Board gave a tacit approval in March to the staff to continue the examination process pursuant to the previous guidelines.  The staff proposals are vague and confusing, and we have outlined some of our concerns in Posts made December 4th, April 18th, May 1st and May 24th.  But as the Board considers the industry’s objections to the proposals, the staff presses on with the scheduling of examinations.

At its May meeting, the Board established a Rules Committee to take up the stalled record keeping proposal (and other rule proposals that have grinded to a halt).   Now, the Board has scheduled a Rules Committee meeting for June 30th at 8:00 am.   This is the time for sellers to begin making suggestions to the Board and the staff regarding recordkeeping and the examination process.  But, the recordkeeping requirements must be addressed first.

The principal purpose for Senate Bill No. 1 is to ensure that consumer funds are handled properly.  Accordingly, the examiners need the type of records that reflect all funds handled by the seller, and that such funds were transferred to the funding agent (depository accounts, trusts or insurance) in a timely manner.  For purposes of that discussion, we have submitted this proposal to the Board.