Does an FAA IR not 'freeze' the exams anymore?
It never did for initial issue. You have (and had) to have applied for the issue of both a JAA CPL and a JAA IR within the thirty six months.
The thing that changed in December 2010 was:
Prior to that date, an ICAO IR kept your JAA IR 'current' so that you could let your JAA IR lapse by as long as you liked providing you kept your ICAO IR current.
After that date, an ICAO IR no longer keeps your JAA IR current if you let your JAA IR lapse for more than 7 years. So, even if your ICAO IR is current, you would have to redo your ATPL ground exams if your JAA IR lapses for more than 7 years.