If your going to RMA a card because you made a mistake flashing the BIOS then there is no reason that the company should provide you with a new product. There are quick test benches they can use to determine what is wrong with the card. It's not like they need to plugh it into a computer and start it up like us. It's simply a dock they plug the card into, it runs a few test, and out pops a reason the card may not be working. It will check the BIOS, the chip, memory, etc. to see possible reasons. However, not all cards are tested like this before RMA's are completed. You will be luck if they provide you with a card at all. I wouldn't be complaining I would be hoping that they don't test it and just fill your RMA with any card at all.
AFAIK alot of people get away with just RMA'ing it. And sometimes they give u second hand cards.