The Missouri State Board’s proposed exam handbook would have examiners perform more of their review before an onsite visit is scheduled at the funeral home. By performing a desk top review, the examiner would be better prepared when visiting the funeral home. This should expedite the examination process. There would be four stages to the desk top exam that starts with an information and document request.
Depending upon the sampling to be used by the Board, the examiner sends out an initial examination notification to the seller explaining the sampling process and requesting: 1) all preneed contract forms used since Seller’s previous exam, 2)an outstanding contracts report, 3)a serviced/canceled contract report, 4) copies of specified months of financial transactions (consumer receipt and funding agent transmissions), 5) identification of all funding agents, and 6) whether Section 436.031 income distributions were taken, and supporting documentation. The seller would have 30 days to provide the contract form and contract reports, and 60 days to provide the other requested information and documents.
The second stage would involve a review of the seller’s annual reports for consistency in assigning sequential contract numbers, and for gaps in reported contracts review could be performed while the examiner waits for the contract forms and reports.
The third stage begins when the examiner receives the seller’s contract forms and contract reports. Depending on the sampling that applies to the seller, the examiner will specify which outstanding contracts and performed/canceled contracts are to be made available for review during the on-site visit. After sending a notification letter with the specified contracts, the examiner would then proceed to review the contract forms for Section 436.425 compliance. This should save the examiner substantial time since the prior exam procedures required that he/she review each outstanding contract for disclosures compliance.
The fourth stage of the desk top exam would begin when the examiner receives the funding agent information, financial transaction reports and Section 436.031 distribution documents (if any). From the seller’s consumer receipt records, the examiner will reconcile those with the corresponding transmission records and funding agent reports. If there are any Section 436.031 distributions, the examiner will determine if the records are sufficient to confirm compliance with the statute.
During all four stages, the examiner will note issues or exceptions to discuss with the seller. When the fourth stage is complete, the examiner will contract the seller to schedule the on-site visit.