On December 28, the CFPB published a final rule to clarify what events constitute the “issuance” of its rules. As explained by the CFPB, an agency may treat events other than publication of a rule in the Federal Register as events constituting the issuance of a rule. In some cases the date of issuance of a rule has legal consequences. Pursuant to its final rule, CFPB rules will be considered to be issued on the earlier of the date that such rules are either posted on the CFPB’s website or published in the Federal Register. The rule took effect immediately.