16 CFR 453 Every required disclosure and price list, checked provision by provision — not assumed

The most rigorous Funeral Rule completeness pack an independent funeral home can adopt.

GPLClear assembles a documentation-complete Funeral Rule pack — a gap-scored, corrected General Price List, the Casket and Outer Burial Container lists, a written telephone-price-disclosure policy, staff attestations, and (on Full) an independent mystery-call scorecard — checked against the letter of 16 CFR Part 453 before a compliance specialist releases it.

Scored against 16 CFR Part 453, provision by provisionAll six required GPL disclosures, gate-checkedTelephone-price-disclosure policy, in writingCompliance-specialist release on every pack≥95% required-element score, or we rework it free
Why homes fail a sweep

Funeral Rule failures are operational, not dishonest.

Staff fumble or refuse a telephone price question; a home hands out a package sheet instead of a true itemized General Price List; a routine price update quietly deletes one of the six required disclosures; a cremation-menu edit breaks the list structure. None of it is fraud — all of it is a violation.

The FTC's first undercover phone sweep produced 39 warning letters in January 2024. Civil penalties run up to $53,088 per violation, and the usual first-offender path costs about 0.8% of average annual gross sales plus fees and three years of monitoring. Most homes have not read the Rule end-to-end since their price list was last built.

GPLClear exists to close that gap with a single, exhaustive standard applied identically to every price list.

$53,088
maximum civil penalty per Funeral Rule violation
The benchmark

Measured against the letter of the Funeral Rule — provision by provision.

We do not summarize the Rule and hope. Every pack is scored against a versioned checklist tied to the exact text of 16 CFR Part 453, and the deterministic gate fails closed if any required element is missing. These are the provisions each pack is held to.

16 CFR § 453.2(b)(4)

Six required GPL disclosures

The General Price List must contain all six required disclosures and mandatory statements; any one missing fails the gate closed before release.

16 CFR § 453.2(b)(4)(iii)

Itemized, no forced package

Prices must be itemized across the required categories with no forced package purchase — the packages-only substitution is a red-team trap in every scoring run.

16 CFR § 453.2(b)(4)(iii)(A)

Basic services fee

The non-declinable basic-services fee must appear once and be unique; duplication or omission is flagged.

16 CFR § 453.2(b)(2)

Casket Price List

A Casket Price List is required, with the alternative-container disclosure for direct cremation present and correctly worded.

16 CFR § 453.3(a)

Telephone price disclosure

Price information must be given over the phone on request, without requiring the caller's name — backed by a written staff policy and, on Full, a consented mystery call.

16 CFR § 453.2(b)(5)

Statement of Goods & Services

The itemized Statement of Funeral Goods and Services Selected is drafted to template so the pack is complete end-to-end, not just at the GPL.

How a pack is built

Gap Scan to specialist release, with a rule gate that fails closed.

AI extracts and scores. Deterministic rules — running as code, outside the model — decide whether every required element is present. A compliance specialist releases every pack, and no price is ever computed or altered by the model. That order is never reversed.

01

Free GPL Gap Scan

Upload your current General Price List. Within one business day you get a one-page Gap Scorecard with your top five required-element gaps — the presence of Rule elements on your document, not a legal opinion or a penalty prediction.

02

Extraction & scoring

OCR reconstructs the list, separates packages from itemized pricing, and captures footnotes and third-party-casket language. Each of the six disclosures is detected as present, partial, or absent — prices are copied verbatim, never computed.

03

Rule checklist, fail-closed

The deterministic layer evaluates the required categories, the six disclosures, basic-services-fee uniqueness, alternative-container language, and effective dates. Any missing element gates the pack closed — the model cannot override it.

04

Redline draft & phone policy

We draft a corrected redline of each list and a plain-language telephone-price-disclosure script and staff policy synthesized from your confirmed prices — every draft labeled for specialist release, never as legally sufficient.

05

Specialist release

A compliance specialist releases the pack against the internal Rule checklist only at a required-element score of 95% or higher; below that, we rework it free until it passes, before you adopt it.

06

Mystery call & adoption (Full)

On the Full pack, two consented mystery calls test your staff against the phone-disclosure duty; a failed call triggers a 14-day remediation loop. The director confirms prices, staff attest, and the home remains the duty holder.

The bar we hold

Rigor you can measure.

≥95%
Required-element score
Or we rework the pack free until it passes, before you adopt it.
1 day
Gap Scan turnaround
A one-page scorecard of your top five required-element gaps.
100%
Specialist-released
No pack ships without a compliance-specialist sign-off.
6
GPL disclosures checked
All six required disclosures detected as present, partial, or absent.
Why GPLClear

Built to be the most thorough option a funeral home has.

Documentation-complete, by design

The deliverable is completeness itself — every required Rule element present or explicitly flagged, scored to a 95% floor before release. Nothing is left implicit.

Deterministic, not vibes

The gate that decides completeness is code that fails closed, not a model's opinion. Prices are copied verbatim; the model never computes, rounds, or invents a number.

In its lane, on purpose

We prepare documentation and training support and mystery-shop with consent. We are not a law firm, never claim a document is 'FTC-approved,' and the director adopts the prices and remains the duty holder.

Engagement

Flat fee, per location. No contingency, ever.

This is preventive compliance work, not recovery — simple, predictable pricing aligned with a completeness standard.

  • A free GPL Gap Scan before you commit — a one-page scorecard of your top five gaps in one business day.
  • Standard Completeness Pack at $899 per location; Full at $1,499 with the CPL, OBCPL, Statement, two mystery calls, and 14-day remediation.
  • A Monitor Desk from $249/mo to ingest price changes, re-mystery quarterly, and re-score annually — cancel anytime.
  • A completeness guarantee: score below 95% on required Rule elements and we rework it free until it passes.
FAQ

Questions, answered precisely.

Is GPLClear a law firm?
No. GPLClear, a service of Your Deputy, Obuke LLC, provides documentation-completeness and training support. It is not a law firm, does not give legal opinions, does not represent anyone before the FTC, and is not a substitute for licensed counsel or the NFDA-administered Funeral Rule Offenders Program. An optional counsel add-on is available if you need legal reliance.
Do you guarantee we'll pass an FTC inspection?
No. We improve completeness and readiness against 16 CFR Part 453, and we never claim a document is 'FTC-approved.' We do not and cannot guarantee how the FTC would rule. The Gap Scan reports the presence of required Rule elements on your document — it is not a legal opinion or a penalty prediction.
How do the mystery calls work?
On the Full pack, we place calls to test whether your staff give price information over the phone as the Rule requires. Calls are recorded only with consent as required by applicable state law and with your written permission to evaluate your own staff. A failed call triggers a 14-day remediation loop at no extra charge.
What makes a pack 'complete'?
Completeness is defined by the Rule: all six §453.2(b)(4) GPL disclosures present, required categories itemized with no forced package, a unique basic-services fee, the Casket Price List and alternative-container language, and the telephone-disclosure policy — scored to at least 95% and released by a specialist.
How are you priced?
A flat fee per location — $899 Standard, $1,499 Full — with an optional monthly Monitor Desk. This is preventive compliance work: never hourly, and never a contingency or share of any penalty avoided.

Find out whether your staff would pass a phone sweep tomorrow.

Start with a free GPL Gap Scan. Upload your current General Price List and we'll return a one-page scorecard of your top five required-element gaps against 16 CFR Part 453 — in one business day.

Documentation-completeness and training support · not legal advice · the funeral director remains the duty holder.

[PLACEHOLDER] First-cohort GPL remediation turnaround — our target is a 14-day remediation window on a failed review. The real measured turnaround appears here once the first pilot funeral homes complete a cycle.

[PLACEHOLDER] First funeral home reference — added only with a named pilot client's written permission. GPLClear never invents a testimonial or a funeral-home name.

[PLACEHOLDER] Total GPL reviews completed to date — a live, auditable count once real reviews have shipped, never estimated.