FotM is the reason why. /shrug My HD 7950 (R9 280) has it. Wear headphones while gaming so its pretty much unnoticeable.
AKG 271 mkIIs are not enough, for mine. FotM is not the reason. That it's really bad on some samples, and not easy to avoid by avoiding certain models, is the reason. I've been aware of and avoiding such noise for many years, and it's usually not hard to do, based on vendor and series of card. If, for example, the whine was bad with the Zotac, and you could just get an Asus, it wouldn't be nearly the fuss it is (and, that's the situation the Radeons were in, with Asus' and Sapphire's fancy-pants models being more or less clear of whining,
generally, on models where it was fairly common).
My GTX 460, now reinstalled, makes some noises when syncing the display, and going from idle to full clocks, and the reverse. It makes no audible noise, aside from the fans (grrr), outside of those small rare fractions of seconds, even if I put my head right near it, much less in a closed case some feet away. It can use a little more power than an official-TDP GTX 970.
My inner cynic says they need ten times more copper, and it will, overall, cost less than a few dozen RMAs, and/or nothing (if the card needs to be $5-10 more at retail, that's not going to sway buyers away, at $300+).
Side note:I don't remember reading any coil whine issues from the major website reviews of 970.
http://www.bit-tech.net/hardware/graphics/2014/09/19/nvidia-geforce-gtx-970-review/14
That's the only one I know of. But, review sites likely got cherry-picked pre-production samples.
I've also read before that in the big cities over in HK and Taiwan, there are no quiet places, and that they won't even hear this stuff (scary). But, if it truly is that bad, sound proofing is not magic, and that is a completely fixable problem. Selling to the West, it is also an important problem to deal with. They got away with it back when we were constantly after the next fastest component, due to nothing being truly good enough for even basic tasks, but those days are long past, and environmental concerns matter.