I didn't do a 'Factory Reset' on my 272 - it was fine, with notable increased SQ.
Then I did a 'Factory Reset' on my 272 - it was still fine, and still with the same notable increased SQ.
It seems as though the NDS may have a particular specific reason for benefiting from a factory reset (and, as it does good to some and no harm to others, that would be enough justification for including it in the instructions).