Are the UMR vacant billets still required for CPL promotions of those E4's with BLC complete?

As I understand it, a company commander can promote a SPC to a CPL under the scenario where there is a vacant E5 billet open on the UMR, and no other MOSQ E5 is on the books for that billet.

Now that SPC's are eligible for CPL upon completion of BLC, does that MOSQ/Vacancy regulation still hold true?
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I've once promoted a SPC to a CPL (it was my 1SG's pet project to do this for high speed SPC's), but in that process it wasn't as simply as signing a promotion form. There had to be an open E5 vacancy without anyone on the books to fill it.

Now, as I reflect upon all the pro/con's of "oh no, we are going to get slammed with CPL NCOER's" I don't think that will happen. I think the new BLC grad's and CPLs wont go past 12 months before they pick up SGT anyway and get a typical NCOER as SGT's and never actually get rates as CPLs.