Unlock LG Phoenix 4

It is not an FCC violation to refuse to unlock a phone because the code is not available. 

Unlocking is voluntary per CTIA agreement. 

If AT&T is unable to access unlock codes for any reason, they cannot possibly provide them to you.  If AT&T is unable to unlock a phone for any reason, the phone will not be unlocked 

https://www.ctia.org/the-wireless-industry/industry-commitments/consumer-code-for-wireless-service

Examples of phones that can no longer be unlocked: 

The red hydrogen One, Amazon's fire phone, And the first few generations of iPhone including the original iPhone iPhone 3 g, iPhone 3GS, iPhone 4.  Old analog phones.   Old 2g only phones.  Old 3G phones from manufacturers that AT&T no longer supports, like Panasonic and Sony for example. 

However ... The Phoenix 4 should still be supported by LG. That does not mean it is eligible for unlocking.   

    In order to be eligible for unlocking, the phone has to be registered on the AT&T network (in order to be registered the phone has to be activated on, and used on the AT&T network. If the phone has been removed from the network it is no longer registered). 

    That phone was sold for prepaid so it had to be used on AT&T prepaid for a minimum of 6 months.    

AT&T confirmed that the phone is eligible to be unlocked.   I thought it might be a violation by LG if they won't provide unlock codes.

LG no longer makes or sells phones so they don’t care anymore.

LG has no skin in the game anymore.  If AT&T doesn't have the unlock code and LG is unable to provide it because they have purged that information then the information no longer exists.  

There is no FCC violation and never was. There is no requirement that phones be unlocked.

Phone unlocking is voluntary 

It was a cheap phone to begin with. It will only work in North America and South America, nowhere else in the world. Just replace it