I have seen a thread somewhere where a guy flashed his Asus DCUII with a gigabyte Bios to get it to run stable at higher clocks. (this was after unlocking etc) Asus's uses a different voltage controller which has lower voltages than most 780's, so the Gigabyte bios treated the card like it was a normal card voltage wise so yes too much or too little voltage can be a problem.
This (possible) issue with the voltage tables in the BIOS is actually more complex than it might appear at first.
I give you an example of an EVGA SC ACX2.0, but I've seen this in pretty much ALL BIOS for GTX 970, EVGA, Gigabyte, Asus, MSI...I looked at a lot.
* First, the voltage table, means the increase in voltages per clock in the table is of course not linear. It's NOT that the same value is added with each higher clock rate.
* The maximum voltage specified in the BIOS for the max boost clock can be WAY, WAY higher than what the card (voltage controller) can actually provide.
My EVGA can only supply an absolute maximum 1.212V, yet the voltage table specifies 1.870V at clock 74. ALL Bios I looked at have as the last voltage at the end of the table some way high value they cannot even specify.
* Now, all cards are different, not only with their voltage controllers (some are programmable and might INDEED allow increasing V, some are volt locked to 1.2)....of course all cards don't boost to the same clock entry either. (ASIC quality might play a role etc. Some boost to 1380 stable, some to 1447 etc...)
BUT THE BIOS, at least the voltage table entries, are pretty much the same for all those cards even with these differences in hardware. Which means that this table is not/cannot be optimized for each and every specific card. Which also means that most cards (in my opinion) would benefit from a custom-modifed BIOS where the voltage table (aka: The voltages for each particular clock) are adjusted accordingly.
As a result, and especially since the table is not linear, it's *possible* that some cards don't get the right voltage at certain clocks. This is my THEORY.