My best guess is to properly align instructions along a certain boundary, but I'm pulling that out of my hat.
You can put bcopy as a function call right before memmove, and then you don't need one function to call the other, which would cause a stack push. Maybe instructions need to be at addresses = 0 mod 16, so that's the "closest" you can get it. And spinning over ~12 NOPs might be faster than incrementing the PC by ~9.