Ten years after the collapse of NPS, the Missouri State Board of Embalmers and Funeral Directors has a confidence problem with licensees and legislators. Licensees see a regulator that is obsessed with DBAs, renewal reports, and exams that focus on contract provisions. Legislators see a regulator that will not fulfill the SB1 mandate to protect
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The Missouri Board Chairman’s Rally Cry: Follow Me, Boys!
Pursuant to a notice that may, or may not, satisfy state law, the Missouri State Board of Embalmers and Funeral Directors met in closed session this morning. At the State Board’s December meeting, Division counsel advised that 24 hours’ notice to the public was required to amend the Board’s agenda. Notice of this 9:00…
Missouri Seller Records: The Starting Point for an Audit Trail
The last time the Missouri State Board of Embalmers and Funeral Directors took up the issue of preneed seller record keeping requirements, the staff proposal emphasized a contract ledger approach. The proposal sought to require a contract record that reflected the amount and date of each payment received and the corresponding dates and amounts…
Missouri’s Preneed Examination Process: A New Focus
For the first round of Missouri preneed examinations, the State Board of Embalmers and Funeral Directors had no choice but to jump into preneed sellers’ records and files. Hundreds of funeral home had been selling preneed for decades without supervision or record keeping requirements. So, the first exam objective was to look at everything and…
Missouri’s Funeral Board: Returning to the Scene of the Crime
Two years ago, the Missouri State Board of Embalmers and Funeral Directors met in Independence to discuss their staff’s recommendations for seller record keeping requirements and the scope of preneed examinations. As the minutes somewhat reflect, the staff proposals were met with strong public opposition. (This blog documented those issues in prior posts that…
Missouri Preneed Examinations: An Important Pivot
In their last meeting, the members of the Missouri State Board of Embalmers and Funeral Directors took a small, but important pivot in the preneed examination process. The State Board approved a recommendation made by the Financial Examination Committee that the Committee review each examination report and prepare the letter that accompanies the report to…
Missouri Seller Records: 2017 Reboot?
This time last year, the hot topic before the Missouri State Board of Embalmers and Funeral Directors was the staff’s proposed regulation to define what constitutes adequate records of a preneed seller. The proposal was revised more than once during 2016, but it was eventually tabled by the Board before any consensus could be reached. …
Missouri’s State Board: the 2017 Sabbatical is Over
After a 8 month sabbatical, the Missouri State Board of Embalmers and Funeral Directors will be back at work soon. Shortly after taking office in January, Governor Eric Greitens withdrew two interim appointments to the State Board, leaving it without a quorum to take formal actions. For the last eight months, the State Board has…
Missouri Rule Rollback: How to Start the Process?
Despite lacking sufficient members to take official actions, the Missouri State Board of Embalmers and Funeral Directors met last week to discuss Executive Order 17-03. As we reported back in January (Missouri Rule Rollback), the Order represents a significant undertaking by the State Board. Seven months later, the State Board has less…
The MFT Complaint: A Sham Seller
In paragraphs 53 through 71 of the MFT Complaint, the State Board sets out certain duties that only a licensed Missouri preneed seller may perform. The Complaint asserts that these seller duties are either being performed by the funeral homes that contract to be ‘providers’ with the MFT, or by Eagle Bank as trustee for…