Uhm, most stock intel or AMD cpu coolers are able to run at 3-6k rpms.Nobody in their right mind would just set this coolers on MAX and whine about the noise.
This whole "issue" is not an issue.People doing MAX overclocks are either using water or are just doing benching, where noise is not a problem.
Everyone else is buying cards with better (and not blower type) than reference cooling ,and also if someone is looking for a OC in day to day situatuns like gaming, theyre OCing up to a noise threshold they desire.
In any case, MAX overclock is pretty much never usable because of the inefficiency, power and loudness.I CAN go 950 on my HD6950, however i have to go MAX fan and the card uses insane power amounts, so i run it at 900 with a quiet fan ,difference of few percent isnt worth the trouble.
Whats even more interesting, is the fact that we dont really know how loud reference of this even is!