... ab initio , because the Director specifically ignored the mandate in N.J.S.A. 54:1-35.25b(a)(2) to adopt a regulation delineating circumstances warranting the ... established the procedure for the renewal of tax assessor certificates. N.J.S.A. 54:1-35.25b(a). Important to our discussion is the continuing education requirement ... requirements for continuing education may be granted by the director. [ N.J.S.A. 54:1-35.25b(a)(2).] The statute also includes an enforcement provision, found ... Failure to comply with requirements for continuing education pursuant to [ N.J.S.A. 54:1-35.25b,] shall cause the automatic revocation, without a hearing, of the ... an eight-count declaratory judgment action, asserting the Director violated N.J.S.A. 54:1-35.25b and misapplied N.J.S.A. 54:1-35.29 ... opinion, the Law Division judge found the plain language of N.J.S.A. 54:1-35.25b(a)(2) demanded the Director adopt a regulation specifying ...