This is true for the most part. Most games will run just fine with 2GB of vram at 1440p.
Crysis 3 would be one of those exceptions however.
Source
With FXAA 2GB would be just fine but higher settings and you might be hitting the swap file. This is a moot point with one card because no 2GB card has the GPU grunt to enable higher AA modes, but with SLI/CF your vram could become the limiting factor.
Hitman Absolution looks to be another title that needs a lot of vram. This is a quote from [H] concerning 5760x1200.
"In the apples-to-apples test we have 2X MSAA enabled, and you can see that TITAN is literally over 100% faster. The reason is because GTX 680 SLI is severely bottlenecked at 2X MSAA due to its limited 2GB framebuffer, it isn't achieving the highest possible framerates it could, due to that limit. Therefore, TITAN is able to outshine it and achieve its full potential of performance in this game, which is amazing."
Regarding 1600p and 4xMSAA
"With the GeForce GTX TITAN we were able to play this game at the highest in-game settings with no less than 4X MSAA enabled at 2560x1600. To this date, no other video card has been capable of giving us that level of performance. The 2GB GTX 680 struggles at 4X MSAA because of its VRAM limit, and the 3GB HD 7970 GHz Edition struggles because it just isn't fast enough at 4X MSAA in this game.
The minimum framerate is also important, as in this game, with VRAM being a limiting factor, it can drop quite low. The GeForce GTX TITAN only drops to 39 FPS at 4X MSAA, which is amazing, while the GTX 680 with 2GB drops to 29 FPS, and the 3GB HD 7970 GE drops to 34 FPS. "
Source
Here are some Skyrim benchmarks I did last year. I wish I had a 2GB card to test against at the time to see if the amount of vram allocated was close to the amount of vram used.