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I think the Horde rules only apply when playing an "Epic" game with LOTR figures and rules. I could be wrong.
Again, not having the actual rules means most of this is coming out of the butt, but it seems to be that "Epic" is a classification that has a minimum of 400 points, and may or may not have new stuff beyond what we know. Epic actions are the main 'new' feature [respawning Hoards is the other we know of], and, yeah, so far only LOTR guys have Epic abilities or Hoards. But there's nothing that I see that prevents you from playing an all-DC Epic game, other than the fact that [maybe] it'll be no different at all.
That said, to do with what you're saying, I'm pretty sure Hoard guys are perfectly usable in a 200 point game, for example. They just won't be able to respawn. [It also looks like the "you lose if you only have Hoard dudes" might be an Epic-only stipulation.]
Although I'm thinking that Epic may also have different actions-per-build total levels, perhaps a different application of Leadership, and [I'm hoping] greatly revised [or scrapped] "theme" benefits.
Pondering out loud, I think Hoard tokens coulda been good participation prizes in the OP kit... although making Hoardies with the same name but different powers would be overcomplicated, I think. The gracefulness of the system relies on the stack all being identical.