Need? No. And as far as MSI goes, I don't think there were too many cards that got the vBIOS update anyway.
MSI were one of the few manufacturers who were pretty firm on the vBIOS updates not boosting the VRAM clocks though - as the memory chips were only validated for 12Gbps and there was no guarantee any of their cards could do the 14Gbps in the long-term.
I know there were revisions to be released, running 14Gbps, but unless a product description specifically states as such... it's probably not one of them.