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I mean, arguably yes, but you could say that about anything. Why did they bother with that Black Panther movie, when they could just have invented their own magi-tech African nation to tell their story in?
The answer comes down to three things: name recognition, exploration of a fictional universe, and (as you say) making money. Does the Nazgul of Numenor concept hit these? I'd say yes:
-It's about Middle-earth, and features both Sauron and the Nazgul. It centres on the use of Rings of Power, and has a heavy association with elves (including named movie characters like Galadriel and Elrond). Throw in careful setting design to evoke the Middle-earth 'feel', and you have a pretty hefty chunk of brand recognition.
-The events surrounding this are canon. The War of the Elves and Sauron took place, with Sauron seizing the Rings and using them to corrupt Men. Three of those Men were Numenorean nobility. Tolkien said that the Ringbearers gained power and influence (and wealth) in their homelands; it's a fairly simple deduction that the three Numenorean Nazgul were probably political movers and shakers before they left to work directly under Sauron.
Minastir and Ciryatur are actual people, and it's a fact that, according to the records, Minastir sent Ciryatur to relieve Lindon, despite the fact that his aunt was still on the throne, and had previously not intervened. We know what sort of person Telperien was - that she clung to power, and that she refused to marry in order to keep it in her own hands. Minastir's 'rebellion' is presumption, but it's a very logical one.
Would things have to be added? Absolutely - but they do in every adaptation. Numenor and the Rings of Power are a fairly unique setting, and I think there's enough uniqueness to justify keeping the story there, rather than slapping new names on it.
-Would it make money? I don't know. Non-epic high fantasy isn't a concept that's been well explored, so far as I know. Marvel has proven that you can shift genres within a series (the MCU contains action, comedy, heist, political drama, a whole bunch of stuff), so I think it's quite plausible that 'fantasy setting political drama with horror twist' could sell a bunch.
I mean, obviously it's not being made, and never will be. But it would probably make for a better movie than The Hobbit 7.6: On A Path In Mirkwood.
hS
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