Of course, here's where it breaks: How do you export that over NFS? I guess nfsd would also need to talk to that infrastructure also.
My suggestion about doing it at the kernel level is that you retain the userspace ABI, and there's never an application that breaks because you've radically changed where atime gets monitored and recorded.
I guess you could provide a FUSE-like mechanism to hook userspace back up to 'stat'.
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