There are lots of subtle ways carriers can punish unlocked phones. I tried using an unlocked Samsung flagship with a Verizon MVNO and it never worked properly. They even told me that various features wouldn't work such as Wi-Fi calling. Had to go with the main carrier anyway, so I might as had a locked phone. If the FCC pursues this rule they need to cover all the loopholes and even then it will probably be years of malicious compliance like we're seeing from Apple in the EU app store ruling.
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