If this perspective helps -- Before Prohibition, when the term originated, a brewery's "Cream Ale" would have been brewed exactly like their lager, but fermented with ale yeast, and packaged and sold quickly with no ageing. So no dry hops. Other, often stronger, ales (pale, stock, etc.) were dry hopped and aged for up to several months before release, and these would have been hopped more in the boil too.