I was able to take my E7200 to 3.24 GHz wih the stock HSF and with temps below 65°C. The problem I saw is that my cpu fan was running @ 100%, making a lot of noise. When I upgraded to the Thermaltake I have now, I reduced the temps by 5-7°C if I let it run @ 100%.
Or, I kept my temps at 65°C, but the fan runs at lower speed, making lower noise, which I like.