Except that it makes no sense to not RMA a component that is under warranty when it begins to fail.
So, yes, maybe it "works" better when you lay it on it's side, for now, but what about when it doesn't? Are you still going to be within warranty then? Does the vibration, shaking and rattling also kill of some other part of your graphics card, because we already know from years of experience that vibration can be deadly to components like capacitors, batteries and other electronics. You can literally shake an electronic to death, slowly, but certainly. Not to mention what happens if, say, that shake and vibration are due to a bad bearing on the fan and faulty bearing create significant extra heat which could play out multiple different ways including contributing to thermal issues on your card or the fan motor itself eventually (Or even in the near future) overheating and catching on fire.
If you are prepared to purchase a new fan or cooler now, then that's your call. If you are able to disassemble the cooler to double check that the problem isn't simply a loose fastener, then that's a good first step and maybe resolves the issue. Otherwise, much as it might be inconvenient, getting an RMA started is the only thing that makes any sense, ever, when a component that is still under warranty begins to show signs of problems because, the alternative is that maybe YOU end up without a graphics card AND without any avenue for replacement especially if it snowballs into a larger problem and the decide that you neglected to contact them before it got to the point where the card was a total loss. They certainly won't replace any other hardware in your system if your graphics card causes something to else to fail because it has a motor failure that creates a bigger problem.
IDK, maybe your problem isn't that severe, but for me, ANY component that is under warranty and isn't working 100% the way it's supposed to needs to be returned for a replacement before it can create a bigger problem, and it will, almost every time. Even if that bigger problem is simply an unexpected loss of the use of your system for an extended period since you failed to get the RMA process under way.