a couple of points
1. Out of the box Microsoft windows tools stopped supporting formatting storage to FAT32 with the release of XP SP 1 (Around 2005) So storage cannot be formatted using default windows tools if the OS is XP SP1 or later
2. The card cannot be formatted by the android if it is not properly mounted. It cant be mounted properly if it is not FAT32
3. some (most ) SD cards come factory pre-formatted to EXFAT32
4. The best practical approach is to use a downloadable free Utility on a PC to format the card to FAT32
5. No hacking of the android device is required (if you have a windows box somewhere)
6. If you don't have a windows box, borrow one or ask someone to format the storage to FAT32 for You