The proposed regulations (which have not yet been finalized) published in the Federal Register on February 23, 2022 include § 54.4974-1(g)(3) which provides an automatic waiver of the excess-accumulation penalty if a beneficiary completes the year-of-death RMD by the due date (including extensions) for filing the tax return for the year of death. If the year-of-death RMD is completed by a beneficiary by this deadline, this regulation makes filing From 5329 to request a waiver of the excess-accumulation penalty unnecessary. However, it doesn't hurt to file Form 5329 to make the request even if the automatic waiver applies.
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