no, you are 100% INCORRECT! You do NOT have to register securities to file a Form 10!!
Filing a registration statement under the 1934 “Filing Reports” Act
You can become an SEC reporting company even if you never file a registration statement under the 1933 “Selling Stock” Act. To do this, you file a Form 10. In fact, Non-Reporting Companies that trade on the Pink Sheets can move up to the OTCBB by filing a Form 10.
The Form 10 has virtually identical disclosure requirements as the Form S-1.