I think you have a safeguard that you don't have in the gun registry, so it doesn't quite work as an analogy. And that is that for every complaint you file about a violation of the ethics rules, if it's not true it's slanderous and libellous, and you're opening yourself up to a libel lawsuit.
I have no problem with putting in a bar where the commissioner can reject complaints that they consider frivolous or vexatious. There is going to be a transition period where there likely will be a backlog, as there is with any new law.