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These are the questions I asked Ford, and here's their response:
Can the TowCommand brake controller be added later to a 2005 that wasn't
ordered with it from the factory? No.
Will it work in the earlier models? No.
Will an upgrade be available through Ford Accessories at some point? Probably not.
The TBC is tightly integrated into the '05 SuperDuty ABS, master
cylinder and instrument cluster, that retrofit would be very involved,
expensive and trouble-prone.