First off, the good Doctor's right on the money. I doubt this show has a snowball's chance in hell of making it past the pilot, much less getting a full series.
Second, Bass is right on the money. It's probably a script for a vigilante series that was given the Punisher name as a means to get it produced. Don't forget, Marvel's really gearing up its TV efforts, and almost assuredly has been making offers to various established writers to make them pitches. I wouldn't be at all surprised to find out Bernerno got a call from Marvel, saw a dusty rejected pitch for a vigilante show sitting on his desk and thought it was worth a shot. Can't blame the guy for that.
Third, Overlord is right on the money. Kind of... We might not like to admit it, but of course the level of violence is important to the Punisher. I'll get to this more below, but... He's the Punisher! His story is predicated not just on the fact that he's violent, but the scope of his violence. I'll get to it more below, but the two major factors distinguishing the Punisher from other vigilante killers is the efficiency and size of his murders, his cold professionalism and his status as an unstoppable force of nature. I think the Dexter analogy is good. Dexter is the serial killer who's completely stripped of that role's vileness and twisted into a pure hero. It sounds like this pitch is doing the same thing. Admittedly, it's something that happens all the time with violent vigilantes, but I find it repugnant in general, and antithetical to character in this instance. Dexter:American Psycho::TV Punisher:Our Punisher.
Four, I think a police procedural is the perfect fit for a Punisher series. But this particular procedural sounds like the worst. More later.
Five, what's wrong with FX? It has a respectable catalog of shows that touch on adult subject matter without being juvenile. It's like HBO's kid brother, and if you can't get HBO, it seems like a decent enough alternative.
Six, Heroes for Hire. Yes please. And use the "Marvel New 52" pitch I'm going to post up elsewhere shortly.
Seven, I'm going to lay down a dense monster post but I should probably keep it separate from this. Tie down your ovaries, folks.