Yes. Say you just renamed a very big temporary file (think GBs) and it just so happens that it would be a good time for the kernel to sync the directory your file is in to disk, because another file in that directory changed and somebody asked to fsync the directory (or some other condition that kernel finds appropriate - doesn't matter). If you guarantee the order with rename(), you then first need to commit a few GBs of data in order to do this (which would otherwise never happen, because the file is temporary and would go away a bit later). If you don't guarantee the order, you then just commit the directory and you are done.
In other words, kernel currently has the freedom to do what it finds most appropriate and is allowed to by POSIX. Ordered renames restrict that freedom.