When making pastry cream, custard is cooked on the stove. When making creme brulee custard, it's cooked in bein marie. Why?

It's sugar, cream and eggs, heated to a point and then let to set. Pastry cream is a much easier custard to make than creme brulee custard, so why does creme brulee require a bain marie? My pastry cream is just fine when I lightly cook it before letting it set.

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