I also have to add that application and type of weather also make a big difference.
I come from a tropical country and I had a Noctua NH-D14 in my FT-03 (not the mini and yes it fit with no issues) and I would hit in the low 70s with my Noctua specially during the summer months here (temps would go over 100*C outside).
I switched over to an AIO (a lowly H55 with a push pull setup with fans on low - 1000 rpms) and it has only ever hit low to mid 60s at full load during summer months.
So it really depends!
Though I do agree that generally unless you get the expandable CLCs your better off using air coolers! For SFF builds though, that's a different story altogether!