Like everyone else who responded to the Competition and Markets Authority’s consultation on whether to make a market investigation reference for the funeral market, we received an e-mail last week. The e-mail invited us to share our views on whether the said MIR should also cover the delivery of funeral services obtained via a pre-paid funeral plan.
And like everyone else concerned with the state of the current funeral market, we will be submitting our considered opinion on this matter. Which is that yes, there absolutely should be further scrutiny of the funeral sector with regard to the provision of funeral services arising from redemption of pre-paid funeral plans.
This blog has covered the subject of funeral plans on no less than 47 occasions over the years. And our opinion hasn’t changed. On the whole, and with the exception of the Good Funeral Guide Pre-Paid Funeral Plan (which isn’t like any other funeral plan we’ve come across) – we have little time for funeral plans.
We make no apology for again repeating the quote from Thomas Long in his and Thomas Lynch’s ‘The Good Funeral – Death, Grief and the Community of Care’ because it sums up pretty much what we think:
“The ‘buy now, die later’ brand of package deal has meant a lost connection between the sale of funerals and the delivery of them, and with it the loss of face-to-face accountability between buyer and seller that used to provide reliable consumer protection. Now the recipient of the services (the bereaved) and the provider of same (the funeral director) are both perilously out of the loop of the original transaction: a deal often brokered years before, between a commissioned salesperson and the now newly deceased. In such an environment there can be little real accountability.”
Notwithstanding this lost connection between the parties concerned with the funeral, in their consultation on scope of the proposed market investigation, the CMA notes the following:
‘In some respects, the position of the purchaser of a funeral plan from a plan provider may be similar to the purchaser of funeral services at need from a funeral director. In both cases, a lack of clear and comprehensive information about price, range and quality, combined with likely inexperience (as purchasing funeral plans or arranging funerals are generally infrequent purchases) mean that the customer is likely to lack the ability to assess properly the value for money of all the options offered.’
Definitely worth a closer look then.
The CMA’s invitation to offer a viewpoint isn’t restricted to just those who responded to their previous consultation, so if you have an opinion on whether the CMA should be looking at the services provided in ‘redemption of pre-paid funeral plans’, please drop them a line. You have around nine days in which to do so.
Postal address: Funerals market study team, Competition and Markets Authority, Victoria House, 37 Southampton Row, London WC1B 4AD
Email address: firstname.lastname@example.org
Here’s the content of the e-mail:
“In November 2018, the CMA consulted on its proposal to make a market investigation reference in relation to the supply of services by funeral directors at the point of need and the supply of crematoria services (in both cases within the UK). The draft terms of reference excluded from the meaning of ‘services by funeral directors at the point of need’ both the provision of pre-paid funeral plans and the provision of services provided pursuant to prepaid funeral plans.
The CMA has received representations, in response to this consultation, that the scope of the proposed market investigation reference should be extended to include the funeral services supplied by funeral directors in the United Kingdom arising from the redemption of pre-paid funeral plans.
The CMA is, therefore, inviting interested parties to provide views on whether, if the CMA decides to make a market investigation reference, the scope of the market investigation should include the delivery of such services.
The consultation document can be accessed on the Funeral market study case page at: https://www.gov.uk/cma-cases/funerals-market-study
Comments should be provided to the CMA no later than 5pm 13 March 2019.