Though I conclude, like you, that a literal reading of the passage would make that seem so, I highly doubt that's really the case. Because a literal reading of those clauses would mean that the independent review board could only act on dynamic-play red cards when they determine something is not a foul. In other words, if we had a simple careless tackle that wrongly got a red for SFP, they couldn't act. Or perhaps more extraordinarily, if a referee gave a red card for a handling offence in the center circle with no obvious goal-scoring opportunity, they could not act (because, while the red card would be unlawful per question 2, the deliberate handling call would be a correctly identified offence, per question 1). I think someone over-lawyered the language here and it doesn't actually represent how this appeals process is going to work. But I could be wrong and this is just me speculating.