It depends on cooling, and etc. Also do you want to mod bios or just use overclock tool.
The MSI Gaming X allows me to overclock it beyond the 2250 barrier simply with Afterburner and since this card has got but a single bios, I wouldn't want to jeopardize its warranty. The GPU operates at about 60*C with the fan @ 88% as to somewhat ensure to keep the memory cool. I have brought the memory modules to 2300 and mined ETH without stability problems as well as rejected shares for about 12 hours. My 1070 is equipped with Micron memory which has been running stable for weeks at 9.41 Ghz and am also wondering how much more headroom I've got on these modules.