When courts or administrative agencies opine on whether a federal statute preempts state law, they usually do so in the wake of the statute's enactment. But the U.S. Consumer Financial Protection Bureau's (CFPB) interpretive rule issued mid-summer regarding the Fair Credit Reporting Act's limited preemption of state laws comes 52 years after the FCRA became law, and 11 years after the Dodd-Frank Wall Street Reform and Consumer Protection Act established the CFPB.