OK, my interest has been piqued and I did some research and found out I was wrong.
I found an explanation of MPAA ratings by the father of the rating system himself, Jack Valenti. Valenti says I was right that MPAA invited producers to label a movie X without involving MPAA -- it would be a waste of MPAA's time to review the movie. But he also says that NC-17 is just a renaming of X and makes it clear that MPAA would gladly award an NC-17 rating to hardcore pornography. And confirms that no one can apply the NC-17 label without MPAA explicitly rating the movie that way.
That confuses me greatly because I can't see any reason not to let producers self-apply NC-17. Is it the risk that someone would say his movie isn't suitable for children when in fact it is?
Henry And June wasn't X. It was the first NC-17 movie. Likewise, Coming Soon must have been on track to be NC-17 rather than X because it was made after X was renamed. Midnight Cowboy was rated X by MPAA, but came out when the rating system was about a year old, before the X stigma had developed. Within a few years, it would be far less likely for anyone to apply the X label to a non-porn film. (And I'm curious as to how many did).
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