Ahhh so it’s Title 14 Part 25.255 the MAX airframe falls foul of. Spent ages looking through Part 25 yesterday but didn’t read that section (Out-of-trim characteristics).
Whatever the exact reasons, the MAX’s big ass engines mean it fails 25.255 without MCAS. That is why I believe the MAX will never fly again in commercial service with less than three AoA vanes.