I think the intentions behind such a question may be more important than its answer. And, the APA's stance is not really that "it's OK after 2 years." It is not automatically prohibited, as it explicitly is within the first 2 years of termination. The difference in interpretation is important. There is a recognition of burden, and that such burden is on the T to prove no probable harm.
Sexual involvements with former clients: A delicate balance of core values