Forming tetrahedral Cr(III)

Why would one be unlikely in succeeding if you tried to make a tetrahedral complex from Cr(III)?

Is this because tetrahedral complexes are favored over octehedral for metal ions in lower oxidation states? And seeing as this is Cr3+ it would favor octehedral?

Thanks

Cr is d6, so Cr(III) has 3 d electrons. Try fitting those into a tetrahedral and then an octahedral CFSE diagram, and see what the differences are.

OK so the octehedral has a larger CFSE, is that it?