They are the exact same chip, they do things the exact same way. I believe it works sorta this way - AMD makes "Dual Core Chip A", or DCA for short. All DCA's are tested for their ability to reach certain clock speeds. The better DCA's are given the higher L2 Cache, and slapped with an Opteron name on them. The ones that aren't quite as good get the X2 name on them, and are given the lower speed rating, 3800+, etc.
At some point, almost all the DCA's are good enough to all be Opteron's. At this point, they still need to sell the lower speed Opteron's, and the lower speed X2's, so what that means, is that most all the DCA's, whether they're shipped out with an Opteron or X2 label on them, are good enough to be the higher end Opteron's or FX chips. The only thing differentiating them for yours and my point of view (the consumer), is the Multiplier lock.
CPU's achieve their final speed from a Multiplier X the FSB speed, in this case, a default of 200MHz. So the Opteron 165 Has a default multiplier of 9, and with a default FSB of 200MHz, you get 9 X 200 for a final 1800MHz speed. The Opteron 170 for example, is designed to run @ 2000MHz or 2GHz, so it would need a 10x Multiplier to reach 2000 at 200FSB (front-side bus speed). The only certain downside to going with an Opteron 165, versus a higher rated Opteron with a higher Multiplier, is that you need to have RAM capable of reaching higher speeds to end up with a higher final CPU MHz speed. So with the 165 and it's peek Multiplier capped @ 9x, say you wanted to reach 2500MHz speeds..... In order to do this, you would need to have RAM that would run stable at around 277MHz. Normal PC3200 RAM (running @ a default speed of 200MHz) is unlikely to do this.
Anyway, I hope this explained a little. There are other factors too, which I don't fully understand, about dividers and such, that would allow you to run the CPU at higher MHz speeds, while running your RAM at lower speeds, but performance takes a hit when you do this. If I didn't cover anything, just ask another question.