I think they have to, or else the game risks breaking when you try to load them in those places.
An an example, for records, every match the game will presumably try to write to the record memory for each character that was in the match. So if Roy's there, and he doesn't have a slot allocated in records, something's going to mess up. It could be as simple as just if (this.Character.Record == null), return 0; but since the PMBR isn't working with dev kits and they're not in a situation where they can explicitly code something like that, they might have to deal with the fact that it's going to throw an error and crash the game if Roy doesn't have a place to write to memory. At that point, the only valid solution is creating another piece of that data structure where Roy would exist, and that character could send data to after every match.
Honestly, when this is all said and done, I'd love for the PMBR to do a little case study or documentary or something. The process of them modding a game this difficult to mod is amazing to me. : D