That looks right, as I don't see how they could possibly have legal lights or the silly federally mandated 2.5mph bumper.
However, I think even though they don't meet the bizarre federal "safety" requirements they could still have the IIHS crash test it anyway, and hence get a star rating.
It also looks like they got AAMVA to recommend that enclosed trikes not require a motorcycle license, so that's a boon for them (sorry for the spam press release link but secondary sources were even worse): http://www.sacbee.com/2013/11/18/5923704/elio-motors-judicia... .
three wheeled "car" ⇒ couldn't pass car safety requirements, legally a motorcycle