The pre-need shopper found a price. It wasn't yours.

The FTC’s Funeral Rule was written in 1982 and switched on in 1984, and its stated purpose is price competition — in the Commission’s own words, “to lower barriers to price competition in the funeral goods and services market and to facilitate informed consumer choice”. It requires a printed General Price List for anyone who walks in, and accurate answers for anyone who calls. About your website, it requires nothing. The FTC says so plainly: the Rule predates the web, so funeral homes “are not required to display or distribute their price information via any of these media.” The doorway is regulated. The place where families actually shop is silent.

How silent? Count it.

When the Consumer Federation of America surveyed 1,046 funeral home websites across 35 state capitals in May 2022, 18% posted their price lists — the most recent national count that exists, and worth dating, because the number is drifting up. A 14,358-site analysis landed on the same 18% posting anywhere, with only 6% placing prices where a visitor could find them without hunting. Meanwhile the shopper those sites turn away has changed: NFDA’s 2025 consumer study puts price as the #1 stated reason families choose a funeral home — 18%, up from 10% in 2012 — while “we’ve always used them” fell from 27% to 16%.

And this is specifically a pre-need problem. The at-need family, in crisis, mostly calls one funeral home and takes the arrangement conference as it comes. The family planning ahead searches differently — she has weeks, not hours, and her browser fills the role your lobby was regulated for. One father in the FTC’s own rulemaking record described arranging his four-year-old son’s funeral with no prices in advance: “I had absolutely no way to negotiate when they handed me their proposed price… it was not like I could walk out and begin shopping.” The pre-need shopper is the person who still can walk out. She’s deciding right now whose door she’ll never need to test.

Don’t wait for the FTC to decide this for you

Online price posting is the most-debated amendment in the Funeral Rule’s current review — and the review has stalled. The Commission opened it in February 2020, voted 4–0 to keep the Rule, and published an Advance Notice of Proposed Rulemaking in November 2022 with online price display as its first question. A public workshop followed in September 2023. Since then: no proposed rule, no amendment, and a next routine review expected around 2030. Two states got tired of waiting — California requires every funeral establishment with a website to post its GPL’s goods and services with a note that the full list is available on request, and Oregon requires any site that shows one price to link the whole list.

Enforcement, meanwhile, never stalled. After an undercover sweep of 278 funeral homes, the FTC sent 39 warning letters in January 2024 — and the sweep’s report showed why the phone channel the Rule leans on can’t carry the load: price information was unobtainable from 26% of funeral homes after business hours, half answered with estimates or ranges instead of prices, and 37 providers quoted different prices for the same service on different calls. The pre-need shopper browsing at 9pm never reaches your best arranger. She reaches your voicemail, and then the next tab.

The stories that keep prices off websites

“Posting starts a price war.” The best available evidence points the other way. In a California study of 120 price lists — quoted verbatim in the FTC’s own rulemaking notice — funeral homes that hid their prices charged a median 31% more for direct cremation, 37% more for immediate burial, and 36% more for basic services than the funeral homes posting prices prominently. That’s one state and a correlation, not a law of physics — Afterword’s national analysis of those 14,358 sites found no consistent transparency-price relationship — but the burden of proof has flipped: nobody has produced evidence that posting drags prices down, and the measured pattern is that hiding travels with charging more.

“Our price signals our quality.” Consumer Checkbook, in the same record, found funeral home prices “are not related to service quality” — the highly-rated funeral homes were slightly less likely to charge high prices. The economics here is old and settled enough to have a founding study: where eyeglass price advertising was banned, glasses simply cost about 25% more, no quality attached.

“Corporate doesn’t post, so why should we?” They started. In 2017, CFA found none of SCI’s thousand-plus Dignity Memorial funeral home sites posted prices — while charging 47–72% above independent medians. By 2023, 75% of surveyed Dignity sites had price lists somewhere on the site, mostly buried. Corporate has already conceded that online prices exist; what’s left to compete on is findability — and the price-led entrants lead with it: Tulip Cremation’s homepage opens on “Starting at $995”. When your site says nothing, the comparison set is them, plus whatever Google’s answer box assembles about cremation costs without you.

“A starting-at banner is close enough.” It’s the one version of posting that can hurt you. Legacy Cremation Services advertised cremation from $995 while omitting a mandatory $1,895 services fee — the DOJ and FTC sued, a federal court ordered disclosure and $275,000 in penalties, and in May 2026 the watchdog TINA.org accused it of doing it all over again. A teaser number that excludes mandatory fees isn’t transparency. It’s the counterfeit of it, and regulators know the pattern by name.

What to actually post

Post the document you already maintain. The Rule obligates you to keep an accurate, dated General Price List — the work is done; the file exists. California’s statute is a sensible voluntary template anywhere: the itemized goods-and-services list on your site, or a link labeled “price information” straight to the GPL PDF. On top of the full list — never instead of it — plain-language package framing helps the family who doesn’t speak GPL: what’s included and what’s mandatory, in plain words. Every “starting at” figure includes the fees nobody can decline. That single habit is the whole distance between Tulip’s homepage and Legacy’s court order.

The FTC’s website review found about 80% of funeral home sites are built and hosted by third-party vendors — for most funeral homes this is a one-ticket change, not a rebuild, and it belongs on the short list of pages that do real work.

The shortlist is being built either way

Stated demand isn’t subtle: 91% of consumers say they’d compare funeral prices online if they were posted, and 79% think posting should be required. And the prize for showing up isn’t abstract: Service Corporation International carries a $17 billion preneed backlog with roughly 3,800 counselors selling into it. The family planning ahead is worth a fortune to somebody. The only open question is whose number she finds at 9pm on a Tuesday.

Hiding your prices never took you out of the price war — the same-market spreads consumer surveys keep finding, 400% and up for the same services, are the war. It only takes you off the shortlist of the one shopper who compares. Post the list you already keep, in plain sight, with the date on it. The funeral home that answers the question before it’s asked is the one that gets asked the next one.

Curious how your site reads tonight, through her browser? The free Price Page Check does exactly the walk this article describes — is a price page findable, are real figures visible, is the list she’d compare actually there — and emails you the graded report in minutes.