I'm assuming "SMS" means true, original SMS. Most people with iPhones, for instance, are using encrypted iMessage, but the code sent to you from a service provider (Microsoft, etc) will be done over straight SMS, not iMessage. Those basic SMS messages can be intercepted by a duplicated SIM card or setting a phone up with different firmware to basically listen to everything around it, including receiving SMS messages. This is probably not casual identity theft tactics though, right? I wonder if mainstream providers shouldn't start using things like Signal and WhatsApp for the 2FA code rather than SMS.