When the State Board first discussed the seller records proposal in December 2015, the disbursements records drew complaints from industry members that the examination process was delving too deeply into how funeral homes were conducting their business. Some comments were directed at whether examiners would review statements of goods and services to determine if consumers
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Missouri Preneed Records: Trustee’s Deposit Records
In our prior post (Missouri Seller Exams: Timely Deposits), we discussed the receipt and deposit records that funeral homes may be required to maintain. However, to demonstrate that they are complying with the preneed law’s deposit requirements, funeral homes will also be dependent upon the records generated by their funding source to confirm…
Missouri Seller Exams: Timely Deposits
Missouri’s preneed funeral law imposes time requirements on funeral homes that accept consumer funds. For funeral homes using depository accounts to fund preneed contracts, the funeral home must deposit consumer funds with the bank within 10 days. Funeral homes using insurance to fund preneed contracts must remit the consumers funds to the insurance company within…
Missouri Seller Records: KISS
When the Missouri State Board of Embalmers and Funeral Directors met June 30th to discuss a proposed rule defining new record keeping requirements for preneed sellers, one Board member spoke a sentiment that many funeral directors share: keep it simple, stupid. The Board member suggested that consumer receipt records could be as simple as…
Missouri’s June 30th Rules Committee Meeting: Time to Take the Lead
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…
Missouri Seller Exams: Trustee Recordkeeping and Disbursements
The clock is on for the second round of Missouri preneed audits financial examinations, and the Missouri Division of Professional Registration wants to avoid the slow start that plagued the process 5 years ago. Although the State Board has yet to approve the Division’s proposals for seller recordkeeping and the scope of the exams, exam…
Missouri Preneed Seller Records: Receipt Journal
The first record described in the proposed Missouri recordkeeping regulation could actually require preneed sellers to maintain three, maybe four, sets of journals:
(1) receipt and disbursement journals containing a record of deposits to and withdrawals from both preneed trusts and preneed joint accounts, specifically identifying the date, source, and description of each item deposited…
Missouri Seller Records: The State Board Proposal
At its March meetings, the State Board again received from the Division staff a rule proposal that would define the minimum records that a preneed seller would have to maintain. The first recordkeeping proposal was offered last July, but was never discussed. The recordkeeping proposal was subsequently included on the December agenda, but was only…
A Missouri Mid-Semester Cram: the March agenda
The staff for the Missouri State Board of Embalmers and Funeral Directors posted the 779 page agenda for next week’s meetings. Doesn’t the state have a policy against the waste of natural resources? Granted the agenda includes minutes and regulation proposals from several prior meetings, but a Cliff’s Notes would be helpful to know what’s…
Missouri Preneed Seller Records: Trying to Get Everyone on a Similar Page
As reported in several prior posts, the preneed examination process in Missouri has been a work in progress for the past five years. Funeral homes in that state have been selling preneed for more than 30 years without much oversight or recordkeeping guidelines. When the law was re-written in 2009 in response to the NPS…