My opinion on the question posed is, I don't care. Comfortable with the answer being Yes, equally comfortable with it being no.
I can't escape the conclusion however that the RFL's opinion is that they are not. The mini licence round can only happen if they have already concluded Bradford's 'misconduct' is sufficient to warrant their expulsion.
Any clubs involved are little more than a fig leaf and a means of leaving the issue sufficiently vague that our leaders can, in the future, continue to do what in their opinion is best rather than have to follow pre determined rules.
They, understandably, see Bradford as a club they want to retain so don't want to kick them out but if they simply say what has happened is OK then it also has to be OK if it happens to a 'less valued' club in the future. Much easier to cloud the issue and retain the option to make it up as you go along.