If you have a large air cooler, I find that a cutout is more helpful that a motherboard tray since with most cases, you can't get the heatsink back while on the tray since it's too tall.
A cut out in the back of the MB is useful and more so is a removable MB tray. Of course if you have a removable MB, you can always create your own cut out in the tray if you are handy with a Dremel.
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