Keep in mind 'SATA SSD' != '2.5" SSD' as m.2 SSDs can be SATA as well.

Even then, I suppose it how the m.2 vs 2.5" SATA mounting turns out depends on the specific system. E.g. on this PC the main NVMe slot is above the GPU but mounting a 2.5" SSD is 4 screws on a custom sled + cabling once mounted. If it were the other way around and the NVMe was screw-in only below the GPU while the SSD had an easy mount then it might be a different story.