From what I understand, most of the problem comes with the stock fan speeds. If you have decent air flow in your case and you manually set the fan speed to 40-50% in Rivatuner (or similar app), there shouldn't be a problem.
The ones with the single-slot reference cooler still tend to heat up, the stock fan adjustment is heaps better than it used to be but you may still have to set the fan speed manually, and it may get pretty loud depending on how hot it is around where you live.