Mbrooke may be thinking of the situation where an MLO panelboard is allowed in a residence, with six or fewer disconnect throws, if it is service equipment. And that is then complicated by the labeling information on the MLO panelboard itself which states that it is suitable for use as service equipment IF it has six or fewer breakers and it is not used as a lighting panelboard. The latter provision is supposedly related to earlier code cycles and the labelling just has not caught up.
But, given that and given the way that residences are usually wired, I find it hard to think of a situation in which a panelboard with no main breaker would have both feeder breakers and branch circuit breakers in the first place, even if there are fewer than six total.
I guess that a small, old, house could have only six branch circuits total, in which case you might not need a main under this rule.