If you ask me
Yes, you can look at it that way. The FAA will be in CYA mode I suspect. It is a loop hole that they didn't see coming....I'm sure they don't even know what a "shoe selfie" is or that you would need to unbuckle your seat belt to capture one. All quite legal with an opened door. You don't even need to wear any kind of tether up until now. It is in the "just because you can doesn't mean you should" category.