Whenever (if ever) the proposed Rule for 15c2-11 compliance is made effective it will apply to every public company that has inadequate and/or insufficient disclosures. That would definitely apply to FORM 15 filers (ie., companies that have deregistered from the SEC) and to alternate reporting companies (ie., companies that have never been registered with the SEC). I surmise the SEC would no longer (or not necessarily) need to suspend stocks in this category because the burden would be (or should be) placed on the Market Makers (and the piggyback Market Makers) to remove their quotations and other market making activities for the stocks that do not comply to Rule 15c2-11.
Of course, the new Rule would also apply to SEC registered stocks that are delinquent in their filing obligations, but those stocks would likely be suspended for Financials delinquencies and thereafter have their registrations revoked.
To bite the worm of incite is to bite the HOOK of the antagonist . They win .