BusinessRules.CheckRules() not called on DataPortal.ChildXYZ(with param) ByDesign?

I noticed my rules not getting run automatically when I used the DataPortal.ChildXYZ(obj param).  But when I call it with no params ex. DataPortal.ChildXYZ() then CheckRules does get run.

Is that by design?  Am I supposed to do something in my void Child_Create(object param) methods?

MarkAsChild is getting called...so I would have thought CheckRules would too?

Thanks

Sean