New York State Funeral Directors Association

Issued February 26, 2019

Thank you to all of you who responded to our recent member survey asking how the Governor’s proposal on “stretch limousines” may impact your funeral firm.

The results showed that the only two areas of overwhelming concern are: whether hearses would be included in the proposed ban on these types of limousines and if a funeral home’s livery would be subject to a new inspection fee.

The purpose of my memo is to update you on this important matter.

NYSFDA has been in direct contact numerous times with senior agency officials from both the NYS Department of Transportation (DOT) and the NYS Department of Motor Vehicles (DMV) to get more clarity ever since this proposal was first made in January as part of the Governor’s proposed 2019-2020 NYS Budget.

I want to let you know that we have been assured that the proposal does not apply to hearses in any way, and it is not the intent of the Governor or either agency to include them in the limo safety proposal.

In addition, according to the same agency personnel, we have been told that limousines and other livery owned by a funeral home as part of their offerings to families are not categorized as “for-hire” vehicles and, as such, would not be subject to the proposed new inspection fee.

Even then, DOT’s operating authority does not come into play until a vehicle has 11 or more passengers.

While DMV has a requirement for license endorsement for any vehicle that could carry eight or more passengers, funeral homes operating such vehicles strictly for their businesses are not doing so for the primary purpose of providing transportation for compensation and, as such, would not be subject to this endorsement, according to DMV.

Finally, although a significant number of survey respondents do not own “stretch limousines”, the outright ban on these vehicles contained in the Governor’s original proposal has been withdrawn.

However, federal law requires that any limousine that is “stretched” must have a tag/plate affixed inside its door certifying that it meets all federal motor vehicle safety standards.

The Governor’s revised proposal still allows DMV to revoke the registration of any “stretch limousine” without that safety certification tag, which is put there by whichever company that “stretched” the vehicle.

This is all good news for our members and funeral service! However, please be advised that this is where the Governor’s proposal stands as of this writing.

It is still subject to negotiation with the Senate and Assembly as part of the State Budget, which is due to be completed on April 1, 2019, so there is a slight possibility that the proposal could change.

However, NYSFDA will continue to be engaged with all parties until that time to ensure funeral service is not adversely impacted by the limo safety proposal once it is finalized.

I hope this information is helpful to you. Once again, thank you again for your feedback and input!