The frame counters are important for security.
MAX_FCNT_GAP is applied to an increasing FCNT.
The downlink frame counter would need to be reset to 0 on the end-device. Unfortunately a downlink cannot be used to reset it otherwise it would not need to be reset in the first place as the network would already know the correct value.
If the downlink counter is reset on the end-device it may be functional up to the MAX_FCNT_GAP at least and at most the two byte in packet FCNT value (~65k)
As long as the network does not advance passed the 2 byte FCNT value then resetting the downlink counter should work but will not be secure. Over time a 3rd party could reverse engineer the Session Keys given enough packets using the same FCNT values.