There is nothing in the desk review form that prevents someone from expanding on the detail to a level equal to that on the 2000 form. One can even expand the SOW on that form to include viewing the comparables (to whatever extent possible) and the subject's complex from outside the gate.
Granted the problem with doing this would probably be with the client who is dealing with a program that calls specifically for the 2000 form unless other arrangements are made. The issue would often end up being a client that would not understand the whole "form" issue and feel bothered by the need to arrange for a change in form and irritated as "all their other appraisers" never make a nuisance of themselves in this manner.
In the end, if you contradict the certification - even by citing Jurisdictional Exception as the Atlanta HUD suggested, or change the certification on the 2000 or any other form just be aware of the potential pitfalls. As someone pointed out, Fannie underwriters let stuff like this slide all the time but this is hardly reason enough to breath easy after doing so. The problem can appear when the file comes back in the form of a buy back attempt, lawsuit, or state board hearing and then the fine tooth combs come out and their is an attempt to find any reason to push the cause at hand. The initial post proves this as at least one party is considering this issue as a means to discredit one of the appraisers involved in a buy back file.
As to proof of fine tooth combs, read the thread linked below and the attachment and ask yourself if the state board involved would miss a beat in adding something like this to the list of reasons as to why they need to destroy someone's career or use it as the sole reason to do so.
http://appraisersforum.com/showthread.php?t=178644
