If the player in position to receive the snap is at 9 yards the entire time, we have no penalty. Correct?
Very technically, that would be correct, because - very technically - they were never in a scrimmage kick formation, by very technical definition, and they had five linemen numbered 50-79 at the snap.
However, no rules editor, national coordinator, or conference coordinator I've ever known wanted officials to be very technical. The idea is that a player positioned 10 yards behind the NZ looks like a potential punter. Wouldn't look much different at 9 yards. If the down/distance/score/time are right, and there is a guy that looks like an apparent punter at 9 yards behind the NZ - don't split that hair. That's a scrimmage kick formation. In my conversation with John Adams so many years ago regarding SKF, he was very clear that there was to be no tolerance of a team attempting to deceive the opponent by messing with numbering on a scrimmage kick.
Robert