Could be. I wish they'd just say that, then. Makes a lot more sense than "not an RPG."
Obviously, it's been established again and again that such things are subjective. No adult seriously believes his own definition of the genre is the only one - though we can all forget when being passionate.
But instead of insisting on the pedantic logic of subjectivity - then maybe you should consider the merits of the "human way" of dealing with this. Because it's certainly obvious to me that we're not talking about dictionary meanings and strict logic when we're saying ME2 isn't an RPG.
We're talking about what RPGs used to be - and even if it's hard for you to appreciate, some of us REALLY (as in, bigtime) like the features that used to be integral to games of that genre.
ME2 could be a "new kind of RPG" - you can call it whatever you like. It might even be a fantastic action game and there's NOTHING wrong with that.
But the thing is, you see, that those of us who would have strongly preferred more traditional RPG mechanics, actually believe Mass Effect and Mass Effect 2 would have been SIGNIFICANTLY better with certain "old-school" RPG mechanics in place. That's what we genuinely believe. It need not have been turn-based combat or endless numbercrunching. More like interesting character development, satisfying tactical combat, diverse loot system, and things of that nature.
It might be good or even great as it is, but it COULD have been so much better still - but only to enthusiasts who like that kind of game. It would most likely not have suited the casual market, and that's why I would never blame Bioware for going in that direction.
They're not who they used to be, and they're way too big to cater to minorities now. They don't want to interrupt the cinematic flow with cerebral moments that disrupt the movie-like immersion. That's fair. They streamline because they think that's the solution to horrible RPG design - and I agree, it's definitely one way to circumvent design challenges. The main difference between the artist and the businessman is that the artist listens to his heart, and the businessman listens to his audience. I know where Bioware fits in that equation.
I reserve the right to lament that, though, even if I have no right to anything else.