Here is a thread that discusses bulk rise in the fridge
My hunch…or perhaps I read this somewhere…is that a slow colder fermentation can “make up for” a lack of active gluten development via kneading/stretching and folding.
As I mentioned to Wendy above, though, I like to stretch and fold cold long ferments – when the dough is still small/flat – because the top of the dough starts to look a little dry/funny after 12+ hours, and if I’m bringing it up to room temp, after about an hour, I want what I at least imagine to be the warmer outside to get folded into the still-cold inside.