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I had the same issue when I first got my e46 M3 check out my thread.. it wasn't super loud but it was there.
Like you mentioned, other forum members first thought was subframe but I had a feeling it wasn't and that it was coming from somewhere along the driveline. Sure enough it was just a worn front diff mount bushing . Upgraded to a Revshift 80a front diff bushing and it completely went away!
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Jet Black E92 M3 DCT (sold)
Space grey E92 M3 6MT (sold)
Black Sap. F15 xdrive35i M Sport (Daily) current
Titanium silver E46 M3 (OEM project) current
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