TSA Rule... what constitutes "training"?

As I understand the TSA rule on alien flight training -- and please correct
me if I am wrong about this -- anyone who is already engaged in flight
training does not need to undergo the background checks. Now if that's true
(and it might not be), what does a student need to have done to have started
their flight training prior to Oct. 20? For example, if a foreign student
came in and did a 30-minute "discovery flight" on Oct. 15, and logged the
time as a half-hour "lesson", were they already engaged in flight training
when the rule took effect? What if the discovery flight took place in
August, or June, or April, or a year ago?


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