The FTC Funeral Rule has been on the books since 1984. For most owner-directors, the practical question is not whether the Rule applies (it applies to every funeral provider) but whether the three required price lists are accurate, current, and presented at the moments the Rule requires.
This post walks through the General Price List, the Casket Price List, and the Outer Burial Container Price List. The audience is the owner-director who maintains these lists and the office staff who present them to families.
What the three lists are
The General Price List, or GPL, is the master document. It contains the prices for all funeral goods and services the home offers, organized in the categories the Rule prescribes. The GPL must include the specific items the Rule requires (basic services of funeral director and staff, embalming, other preparation of the body, use of facilities and staff for various services, transportation in various forms, references to the casket and outer burial container price lists, forwarding and receiving of remains, direct cremation, immediate burial, alternative container, and the disclosure language the Rule prescribes).
The Casket Price List, or CPL, contains every casket the home offers for sale, by retail price, in either the GPL or as a separate document. Most homes maintain it separately because casket prices change more frequently than the GPL.
The Outer Burial Container Price List, or OBCPL, contains every outer burial container the home offers, similarly organized.
When each must be presented
The Rule sets specific moments at which each list must be presented or offered to the consumer:
- The GPL is offered at the beginning of any in-person discussion of funeral arrangements, prices, or specific funeral goods or services. The consumer is given a copy to keep.
- The CPL is presented before any discussion of caskets begins, and before the consumer is shown caskets in the selection room.
- The OBCPL is presented before any discussion of outer burial containers begins.
The "before" is load-bearing. The lists are not handed over after the consumer has selected a casket and asked the price. They are handed over when the conversation about caskets starts.
What changes trigger a reprint
A price change is the most common trigger. If a casket supplier raises the wholesale on a model the home stocks, the CPL has to reflect the new retail price before the next family meeting in which that casket is offered. There is no grace period for "we will print a new one next month."
Other changes that require a revision:
- Adding or removing a category of goods or services offered.
- Changing the description of an item in a way that affects what the consumer is buying.
- Changing the disclosure language the Rule prescribes when the FTC issues a revision.
The home's name, address, and telephone number must appear on each list. If any of those change, the lists are revised.
The retention requirement
A funeral provider must retain a copy of every version of every price list for at least one year after the date the version was last distributed. The practical consequence is that the home maintains a versioned archive, not a single current document. If a regulator or a complainant asks what the GPL said on a specific date in the prior year, the home produces the version in effect on that date.
Most homes that have been audited can speak to the difficulty of reconstructing prior versions from a Word document that was overwritten each time prices changed.
Where digital tools fit
The compliance question for a digital price list system is not whether it can print pretty PDFs. The question is whether the system handles four specific things correctly:
- Versioning. Every change creates a new version. Prior versions are retained for at least one year, and ideally longer for the home's own protection.
- Effective dating. Each version has a date range during which it was the active version. The home can answer "what did the GPL say on May 8" by querying the system, not by hunting through email.
- Disclosure language fidelity. The Rule prescribes exact language for several disclosures. The system carries those as fixed text the user cannot accidentally edit. When the FTC updates the language, the system updates it once across all versions going forward.
- Print-fidelity output. The PDF the system generates has to match what would have come off a print shop's press: consistent typography, no orphaned headers, the legally required language in the legally required position.
What a clean workflow looks like
For an owner-director using a digital price list system, the day-to-day rhythm:
- Casket supplier announces a price increase effective the first of next month.
- Director updates the CPL in the system. The change creates a new version with an effective date of the first of next month.
- The system retains the prior version with an end-date the day before.
- Office staff use the new CPL for every family meeting from the first of next month forward.
- The prior version remains in the archive, retrievable on demand.
If a complainant later alleges a CPL was incorrect on a specific date, the director can produce the version in effect on that date in seconds.
What is not part of the FTC Rule
A few things people sometimes assume but the Rule does not require:
- A specific font or format. The Rule requires that the lists be in a clear and conspicuous form. Most homes use a serif body face, but the Rule does not name one.
- Online publication. The Rule's text addresses in-person and telephone disclosures. The FTC has signaled interest in online disclosure and individual states have moved toward requiring it, so a digital-first workflow is forward-looking.
- Notarization. None of the lists require notarization or formal witnessing.
The substance of the Rule is consumer protection: the right person sees the right list at the right moment, and there is a record of what they were shown. A funeral home that runs that workflow consistently rarely has FTC trouble. PrepRoom's price list module is built around the four properties above, with the prescribed disclosure language locked at the system level and one-year retention enforced by default.