Your lapsed commercial pilot does not need a Flight Review in a ASEL. The Beard letter applies to a pilot attempting to use the student pilot flight review exemption to not do a Flight Review in another aircraft he or she is rated to fly as a PIC.

The Beard letter also says that you do not need a student pilot certificate once you have a rating in another aircraft. Training and an endorsement is required before solo.

A person needs at least an appropriate rating to log PIC time.