There has been an interesting debate raging in overclocking circles over the past couple of years, and it revolves around the question: "Is cooling necessary for memory?" While I am hardly considered an authority on the subject, and thus, my conclusions are hardly binding, I am going to give you my two cents anyway. On one side, you have a contingency that believes that any effort cooling memory is a wasted one; these people have seen no increase in overclocks when cooling is applied. On the other hand, you have a group of people who would consider inserting RAM into their water cooling loop just to get that extra bit of performance.
Source: clubOC.net