I'm inclined to guess that would be a no-no. Maybe Olantern or one of the other legal minds here in the forums can give us the not-a-legal advice informed opinion on this. Kind of a weird situation; continuing to distribute a free client when the owner of said software no longer wishes it distributed. But I think they could get a takedown order for that pretty easily.
I'll take a crack at this. I think it would depend on what the license to distribute the client states. I assume that's covered in the post-Freedom EULA, even though it's an intermediate user, not the end user, who's doing the distributing.
As with anything else related to the IP of the game, NCSoft starts off with the right to do whatever it wants with the client, including restricting it from being distributed, period. When it uses its copyright to make "copies" by making the client available for download, it can put any restrictions on the download it wants, even if it's making the client available for free. For instance, it could include a line in the licensing agreement stating something like, "Your use of this property is conditioned on your not posting the client for download elsewhere." NCSoft still holds the right to distribute (as opposed to the right to download) until it says otherwise. That language I mentioned is particularly important for a rights-holder to include if it isn't giving away the client for free, as in the pre-Freedom CoH days. Imagine if it couldn't include this limitation: one person could download the client from NCSoft, then redistribute it to the entire world, and NCSoft would be without legal recourse against the whole thing.
Now, if the client is being given away for free, NCSoft can still, in theory, put any restrictions it wants on the exchange. But I'm not sure those restrictions would hold up in court. Some judges, especially those with less experience in electronic material, would simply say, "Free is free, so the person who gets the free copy can do literally anything with it."
Regardless, it's unlikely to get tested any time soon in the real world. Because the client's being given away free, NCSoft doesn't have any financial stake in preventing its being distributed. If it sues someone for distributing the client, it might be able to get an injunction to stop the distribution, but it wouldn't be entitled to damages, because it hasn't lost anything. Pursuing the lawsuit is likely to be more costly than it's worth.
That brings something to mind. We'll know NCSoft is really serious about burying the CoH IP if it starts trying to shut down places to download the game. That means it's paying attorney time to write cease-and-desist letters and perform the kind of analysis I'm trying to do off-the-cuff in this post, all without certain financial benefit. Presumably, its ultimate goal in a scenario like this would be to prevent someone from duplicating the servers (which is definitely a violation of both the licensing agreements involved and NCSoft's IP rights) by duplicating the client (which may not, in itself, be a direction violation).
So, as in a lot of legal situations, the answer may be, "Ask the court when you get sued." Don't you just love the certainty and comfort of the law?
