I would be curious to know when that started, as I know that at least 2nd used to be able to be given by not necessarily master ranked instructors. I thought it was 3rd or higher that required a 5th or higher (the first official "Master" rank in KSW, at least when I was in), as there are a lot of places that traditionally haven't had a lot of higher ranked folks around to do testing.
Around the area I live, any dan testing that was done that actually awarded a new rank (i.e. not part of the "pre-testing" cycle), Kuk Sa Nym was always present. This is from the late 90's on.
Probably a regional difference then, as "SE United States" is a bit easier to get to from Texas, whereas I was training around Sacramento, California. Several of my instructors went from 2nd to 3rd, and a few more from 1st to 2nd while I was training. Also mid-to-late 90's.