Yes. If the restatement and restated SPD will not make it within the 210 day deadline following the end of the fifth plan year. I know several other providers that do this, but also know many more that do not. IDP plans applying for D letters get restated every 5 years anyway, so a new SPD is likely generated from that every 5 years.
Too bad the 5-year SPD rule from the DOL is not lined up with the 6-year restatement period for pre-approved plans.