Firstly, physicians have a boarding process in addition to their licensing. Good luck getting any jobs in a particular specialty if you don't have the required board certification. Hell, there's even boarding in peds and family medicine.
Secondly, theoretically, a physician who isn't boarded in a surgical specialty could technically perform surgery, maybe in an emergency, but you open yourself up to huge liability if anything goes wrong compared to someone who is actually boarded.
Where are you getting this from? Sure, the Houston Conference Guidelines are a vertical, not linear, model, allowing for some flexibility in training, but I pretty sure Div 40 would object to the assertion that you are qualified as a clinical neuropsychologist if you never complete any externship, internship, post-doc, coursework, or other training in neuropsychology.
Where I retrieved my information about the shady element of the general practice medical license has been posted above. Also, if you read the reference I provided, you will see an example of an OBGYN who decided to merge into laser surgical procedures. You have other doctors who may have been trained in general surgery who merge into plastics with a trail of destruction. Again, technically, they are within the limits of their license, does it make it right? Perhaps not.
Secondly, in reference to neuropsychologists marketing or operating without any formal focused training is not new, I have seen many clinicians state they provide neuropsychological, forensic, etc. types of assessment. Should they? In my opinion, no. Can they, sure. How does the APA Ethics Code view this? It's flexible enough to allow practitioners who are in emergency or restricted geographic situations to acquire a certain requisite knowledge within a timely manner with supervision or collaboration to perform these assessments. The code of ethics itself is flexible in that regard. When I referenced externships, coursework, dissertation, internship and post-doc, I was stating that a neuropsychologist technically does not have to achieve every single one of those methods of learning to acquire the knowledge and ability to market themselves as neuropsychologists. For example, person A. might have completed a dissertation on a topic within neuropsychology and a general clinical internship but was lucky to get a post-doc in neuropsychology. In this regard, they didn't take coursework, nor went through externship or an internship in which 50% or more of their time was dedicated to neuropsychology. Person B. could have done all of the above (in my opinion, is the preferred method).
As far as div. 40 is concerned, there is flexibility, and the guidelines themselves are used at the moment in an aspirational context much like portions of ethics code. I think both of us agree that it is preferred more, not less, in which those parameters should be implemented when developing as a future clinical neuropsychologist. At the end of the day, being board certified is not a requirement to practice. I plan on going for ABPP, but I know many others who do not, and that is the rule, not the exception. For us, even board certification in neuropsychology is not required. Until APA or whomever makes it so, you will have people who received their doctorate, went onto an APA accredited internship at a university counseling center for example who administer a WAIS, maybe TMT A/B and some other common NP measures and then call themselves a neuropsychologist, or at least market that they offer such assessment in their practice. Personally, I am not a fan of that. But that is me.