DNA Geeks say 2c is possible at 39cM though the probability is so small it's very unlikely. Dna painter haven't had a submission below 41. Personally I'd be comparing the shared matches they have with each other, if one doesn't match a group the other has or one has a mystery group of matches that's unique to them it throws doubt on the papertrail they have. That may not be the case but I'd suggest investigating the possibility just to be sur.
Both of my parents have a bullet proof set of certs and I ignored the obvious clues for a while but finally target tested a couple of first cousins, those tests were definitive and showed both my parents are NPE's and those first cousins are actually half 1c's. There must have been a permanent breeze around my granny's houses 100 years ago from the neighbours curtains twitching