I think that's true for their 15-12(g) filing obligations (not having to be current when filing the Form 15)
However, I think they have 15-15(d-6) filing requirements (stemming from registration filings like S-8, for example).
In order to file the 15-15(d-6) (which I think is due after 12/31/2020), I do believe they have to be 'current' with their SEC filings.
Still, wouldn't it be funny at our next NR meeting that 22 of us undertake to buy 100 shares each?