If a board attempted to enforce a law or regulation or rule upon an appraiser that didn't exist in the manner being alleged then nobody would think twice about that appraiser suing the board to compel compliance with the laws as they actually do exist.
The point of such a lawsuit would be to settle the legal questions involved. That's a legal argument which hinges upon the "that depends on what "is' is" technicality. It's not a moral argument that hinges upon how people feel about the issue.
It's no different than if an appraiser or an AMC violated the law. Everyone would want that case settled on how the law actually reads, not how the board or the AMC or the appraiser or some appraisers-r-racists activist types wish the law actually required. Moreover, when it comes to disciplining licensees we would want govt to act with a certain amount of restraint when it comes to any ambiguities because getting it wrong exposes the state to monetary damages.
The function of the state appraiser regulator is to regulate the appraisers and the AMCs, not to advocate for one or the other. The State advocates for the State, not the licensees. Same as applies to your driver license.
