No, FINRA is not the SEC. The SEC stopped the reverse split while the Company was an SEC registrant. Once the Form 15 deregistration becomes effective, they can certainly apply to FINRA for the reverse split, which I am sure they will do. They will just become the same as most every other non-reporting pink sheet stock and become a completely dark pump and dump. That will get rid of the existing shareholders and bring in a whole new crew of bagholders.
Lather, rinse, repeat.