With this statement, the bank does itself no favors. The reason why the costs have to be borne by the bank is precisely because the appraisal was carried out in the interest of the bank.
Here I completely agree with you – with this statement the bank does itself no favors (although, as I already wrote, I do not know all the legal basics).
From time to time, advisors fall back on the point "legal requirement" – either out of ignorance (by equating guidelines/regulations with laws), or because they want to "finally settle" the issue (laws are usually immutable conditions that the customer/the bank have to comply with).
There may possibly be a third point: the matter is unpleasant for the advisor himself. As the OP wrote, the advisor inquired in advance whether an appraisal was necessary and passed on the then information ("No") to the customer. Suddenly he finds himself forced (by new regulations or the like) to deviate from the previously made statement and to revise himself (in my opinion also poor communication style within the bank, since this makes their advisors appear bad/incompetent – unless the advisor’s first statement was already made months ago). So retreating to "laws" is a way out for him.