Yes, it's quite likely that the devices are created in the initramfs
You can add a custom initramfs hook to ensure your config file is copied
in place if you like - otherwise this isn't something we're going to try
and fix (we've actually already fixed the kernel to not create those
devices in the first place!)
** Changed in: udev (Ubuntu)
Status: New => Won't Fix
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custom rules file ignored
https://bugs.launchpad.net/bugs/109031
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