The intent behind Issue No. 22 of the FTC Notice to revise the Funeral Rule has us a little perplexed. Funeral providers may charge a lower basic services fee for direct cremations and immediate burials. Issue 22 seems to be asking whether funeral providers must disclose when they do not have a lower basic service fee for direct cremation or immediate burials. The issue is suggesting that these two services should set out that limited viewings or visitations are involved. It seems that consumer advocates have found some funeral providers that include their basic service fee in these two categories, and that consumers should be afforded more warning that the provider is not reducing the basic service fee when the law allows for that.