I don't think that the adage is very good - there have been many exceptions. Some that I recall are David - 1979, Allen - 1980, Bertha - 1996, Georges - 1998 and Floyd - 1999. Here is a link where you can check for others:
There are other significant examples of systems which became hurricanes before they reached 40W and still made landfall in the U.S. A recent example is Luis in 1995 which became a hurricane at 37W. Other classic examples include Donna in 1960 which became a hurricane on September 1st at 12.2N 39.4W. Interesting to note that the great New England Hurricane of 1938 became a Tropical Storm on September 10th at 14.2N 21.5W. Another far eastern Atlantic Tropical Storm was Dennis in 1987 at 25W.
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