"NYPD Counsel" is not an example of an executive branch agency with rulemaking authority. Counsel is an advocate, and they have merely asserted a position with

"NYPD Counsel" is not an example of an executive branch agency with rulemaking authority. Counsel is an advocate, and they have merely asserted a position with reference to the law. Absent some other (unprovided) citation, it doesn't behoove anyone to use loose language here. "NYPD's lead freedom of information counsel refused to release the department's freedom of information guides, citing attorney-client privilege."