Do non-account NPCs count toward puppy slots?

Here's an example. 

Approved litter has three pups. Two have accounts that are approved by admins and added to the ranks. One does not ever submit for account approval and thus cannot be added to the ranks, but is NPCed by the mother and the pack as being alive and around. 

Does that pup count toward the 8 slots or not? And if so, isn't this another loophole toward more puppies, and a rule should be considered that extant puppies MUST have approved accounts in order to exist for more than a few days?