I think a high lr + SGD does maybe a piece of what you're talking about, and I think the most important piece. That is, the curvature can be ignored as the noise from a high lr implicitly optimizes for flatter valleys in parameter space, and I would assume that implicitly carries over to second order stuff as you could make an argument for an implicit sensing in the update step of the diagonal of the empirical Fisher via the noise of ultra high lr gradient steps.
This would imply a more genetic side component to optimization here, I believe? Since this is not a directly differentiable thing, and all of this occurs as the natural effects of a higher lr? (I.e. the evolutionary update rule being, "the parameter spaces that survive, survive". Since the parameter spaces that like to survive tend to be flat, and flatness seems to correlate with generalization, then we have a good thing our our hands.)
Adam on the other hand, I believe explicitly regularizes the update step relative to a biased (I believe, since it's not subtracted from momentum?) approximation of the diagonal of the empirical Fisher, hence being sort of a "anti-SGD" in that sense, I believe. This I think makes it really effective for models where you'll often see the data only once, and the model is ODE-like and needs information>>regularization, which we see with many LLMs these days.
Not sure if that helps any or if that's just rambling at this point, that's what I've got and what that made me think of! <3 :))))