Sure, it'd be a solution for five minutes until someone delids the secure enclave on the gaming card, extracts the keys, and builds their own open source hw alternative.
High-performance FPGAs are actually relatively cheap if you take apart broken elgato/bmd capture cards, just a pain in the butt to reball and solder them. But possibly the cheapest way to be able to emulate any chip you could want.
Interesting, from what I can find online even though it's unique to the vita it's still just the memorystick pro duo protocol under the hood, with a DRM system similar to the one Sony uses for their modern CFExpress Type A cards.