What exactly is the problem with manually trimming the aircraft from 200kts down to Vapp? None whatsoever for a half competent pilot!
I think you are confusing this scenario with the G+Y failure where there is actually a very good reason to be in trim before you lower the landing gear. With no G+Y pressure you loose the stabilizer trim so you want the side stick to be centered at Vapp before lowering the gear and activating direct law.