Is copyright transferred to IEEE upon submission? In the IEEE policy on Electronic Information Dissemination (Section 8.1.9 of the PSPB Operations Manual), it says:

A.2.a. An author-submitted article is the version originally submitted by the author to an IEEE publication. An author includes a completed IEEE Copyright Form during submission of the article to an IEEE publication and thereby transfers the copyright of the article to IEEE.

and then later,

D. E-PRINTS
Before submitting an article to an IEEE publication, authors frequently post preprints of their articles to their own Web site, their employer’s site, or to another server that invites constructive comment from colleagues and provides a publication time stamp. Upon submission of an article to IEEE, an author is required to transfer copyright in the article to IEEE, and the author must update any previously posted version of the article with a prominently displayed IEEE copyright notice (as shown in 8.1.9.B). [...]

This seems to have changed with respect to previous policy. In the past, copyright was only transferred upon acceptance, not upon submission. Transferring copyright upon submission seems to have implications that are negative for the author and for the scientific community: it means that IEEE owns the article even if it is rejected, and that the author cannot submit it to another journal if it is rejected.
However, in my last submission to IEEE, the submission process did not include any IEEE Copyright Form. I was not required to explicitly transfer copyright, nor did I receive any document that states that this has been done.
My questions are then:

if the submission process did not include any copyright transfer, does the copyright anyway belong to IEEE now?

if the copyright belongs to IEEE, am I right that this disallows me from submitting to another non-IEEE journal if the article is rejected in this journal?
Copyright is only transferred during submission if:


  An author includes a completed IEEE Copyright Form during submission


Without the copyright form, there is no transfer of copyright. Even if the form is complete, transfer only occurs under terms defined by the form. For instance, the form might define transfer upon acceptance.