After I paid the dues, and took their certification test, the nice diploma was placed on the wall in my office. Upon further research, I found that:
After reading the statutes and seeing some conflicting statements, I talked to the Appraisal Certification Board directly. Their regulation governs doing property valuations for money. The lady nicely stated that they had checked with the State Attorney General, and they were on firm ground in enforcing the prohibition of real estate brokers doing BPOs for money. She did say that it wasn't a violation for the BPO company to pay for one, only for you to collect for it.
So the risk is all on the head of the real estate broker. It is also true that some are doing BPOs, but sending an invoice for taking photographs in order to not charge "for the valuation." I don't know how this would fly, but my guess is that they would see right through the ploy.
So, before you go to spend money, take tests or put out your shingle, check your state's regulations carefully. The pay for BPOs is not enough to risk your license.