I understand what you mean although my thought is the opposite. These engineers must have simply designed these products using their standard design flow. Everything is our pure conjecture for now, though.
If you're talking about the TRN Black Pearl, I doubt you can hear the dynamic range / noise performance difference b/w standard filters and NOS. Both are well beyond the audible threshold, as tested
here. Unless you use a very, very (unrealistically) sensitive IEM, I bet you won't hear a difference. In fact, actual audio recordings, even hi-res, can barely achieve a 20-bit noise floor---consider microphone noise which can only be lowered by post-processing. The Black Pearl's noise performance in its NOS mode is more than adequate and will be masked by audio content' real, effective resolution.
A potentially bigger issue with NOS would've been the effect of no oversampling, which should be taken care of by the playback side when NOS is used on the DAC side.
The CS431xx's analog, thermal noise level is still decent. It does not need DRE for high quality audio playback. Chips in cheaper dongles have substantially higher noise levels. Still, I would avoid DRE in those chips, too. Because DRE seems to cause all kinds of peculiar distortions in exchange for lowered noise. See
this and
this.