Generally I apply that advice to situations where someone is looking at spending an extra 20-40% on a budget card though.

and on a budget it's generally safe to say that no matter what you buy you'll be turning settings down in a year or two. IMO It's hard to make accurate predictions about GPU requirements a few years out. My standard advice is not to 'purchase for the future' when on a budget - purchase for the present or very close future (eg games on souped-up versions of current engines). I don't expect to see 1080p vRAM usage going up steeply soon. Add to all that the fact that we're sitting on a pretty new/fresh console generation - this is something that typically reins in gaming resource usage for years. Out of 3 games tested in the link we see that only 1 game is actually affected (again, at a 70% higher resolution than our target). 1440p is about 70% more pixels with a correspondingly higher vRAM usage. I feel like the link I provided supports my position fairly well, although I'd much rather have linked to a test showing the results at 1080p (rather than at 1440p).

So far I've rarely seen an official card from nVidia or AMD/ATI which is actually underspecced on vRAM. It's easy to say that of course, but vRAM has been an easy upsell for years.

Msi gtx 960 driver update