The requirements of this paragraph shall not apply to the sale or resale of a product that was manufactured prior to the effective date of this subpart OR THAT INITIALLY WAS SOLD OR DISTRIBUTED IN COMPLIANCE WITH THIS SUBPART.
Am I missing something or does that last part seem to imply that cards can be compliant even if they are trivially modifiable (say via firmware upgrade) to make them non-compliant? I can't imagine them leaving such a big hole in the regulations.
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