United States of America 

FEDERAL TRADE COMMISSION 

East Central Region

Jon Miller Steiger 

Director, East Central Region 

1111 Superior Avenue, Suite 200 

Cleveland, Ohio 44114 

(216) 263-3455 (Main Office) 

Email jmsteiger@ftc.gov 

January 24, 2024

Mr. Paul Connell, Owner

Mr. Terence Desmond, Owner

A. J. Desmond & Sons Funeral Directors

32515 Woodward Ave

Royal Oak, MI 48073

Re: Funeral Rule Compliance Notice

Dear Funeral Provider:

As you know, the Federal Trade Commission (“FTC”) has issued a trade regulation rule 

concerning funeral industry practices (“Funeral Rule”), 16 C.F.R. Part 453. The Funeral Rule 

became fully effective on April 30, 1984, and revisions to the Funeral Rule became effective on 

July 19, 1994. As amended, the Funeral Rule has the full force and effect of federal law.

The Funeral Rule requires that funeral providers disclose prices and other information to 

persons arranging funerals. The Funeral Rule requires disclosure of itemized price information 

both over the telephone and in writing concerning general funeral services and ancillary 

arrangements offered by the funeral provider, as well as price lists for caskets and outer burial 

containers. The Funeral Rule prohibits misrepresentations about legal, cemetery or crematory 

requirements pertaining to the disposition of human remains, including embalming. Certain 

unfair practices also are prohibited, such as embalming for a fee without prior permission; 

requiring consumers to purchase caskets for direct cremation; or conditioning the purchase of 

any funeral good or service upon the purchase of any other funeral good or service. Moreover, 

the Funeral Rule requires that each person who arranges a funeral be given a statement of the 

funeral goods and services selected by that person and the price to be paid for each item. Failure 

to comply with the Funeral Rule may result in penalties of up to $51,744 per violation.

FTC staff has obtained information that, in January and April 2023, during undercover 

calls placed by the FTC, A. J. Desmond & Sons Funeral Directors did not provide accurate 

information over the telephone in response to questions about your offerings or pricings. In 

particular, A. J. Desmond & Sons Funeral Directors: 
A.J. Desmond & Sons Funeral Directors

Page 2 of 2

• Failed to provide accurate information about your prices or services. 

Specifically, we contacted your office on two occasions, and you provided 

materially different prices for the same goods and services on each call.

In FTC staff’s view, the conduct described above violates of the Funeral Rule. While 

staff does not currently intend to recommend to the Commission that it take formal legal action 

against A. J. Desmond & Sons Funeral Directors, you should take prompt remedial action to 

make sure A. J. Desmond & Sons Funeral Directors and its staff provide accurate information 

over the phone about its prices and offerings.

Enclosed for your review is a copy of the business guide “Complying with the Funeral 

Rule.” The guide is intended to help you comply with the Funeral Rule and includes information 

about your obligations to provide accurate information over the phone and accurate 

representations about embalming requirements. If you have any questions after reviewing this 

letter and the guide, please call Sammi Nachtigal at (202) 330-1761. 

Respectfully yours,

Jon Miller Steiger

Regional Director

East Central Region

Enclosure