mettelus
Jim's advice is very sound. Another thing to bear in mind is the "air pocket" that exists around the card itself, so that components are not trapping heat against each other. In a proper environment, less air flow (fan speed) is required to maintain cooling, and the noise from a fan ramps upwards with speed. Enclosed environments (like laptops) tend to have fans that need to run like crazy to keep up. 
 
Also bear in mind that NVIDIA is not a manufacturer, they only control the spec. A lot of the "quality" of the card comes from who is actually making it, so be sure to research this. As an aside, the first ASUS GTX 580 card I received had a solder joint hitting a fan blade. I returned it without issues, and the replacement has been in this machine for over 4 years. A well-designed fan, properly (rigidly) mounted, should not generate as much noise as many seem to allude to.
 
Heat degrades electronics, so if you are seeking potential heavy video usage, a fan-cooled GPU is most likely the best choice (if simply to keep the CPU heat off it, since video rendering is one task that tends to top put a CPU, but Premiere Pro is pretty good about throttling render if necessary).