In my experience, last access time is notoriously unreliable. According to http://technet.microsoft.com/en-us/library/cc781134.aspx ...
"The Last Access Time on disk is not always current because NTFS looks for a one-hour interval before forcing the Last Access Time updates to disk. NTFS also delays writing the Last Access Time to disk when users or programs perform read-only operations on a file or folder, such as listing the folder’s contents or reading (but not changing) a file in the folder."
Apparently, the in memory copy will be correct, but in my experience, you may get a cached value which may be out of date. Also, note that last access time may be turned off by the user, and is turned off by default in Vista and 2008.