Fuck no. That game has rpg depth of a Ratchet and Clank game.
Did you only play ME2 on Normal? The skills you choose to upgrade on your character and the people you have in your party has a huge effect when playing on Insane where every enemy has health+shields/armor/biotic shields so different abilities and ammos make a huge difference. You also can only last a second or two in the open before dieing so dumping bullets is usually never a real option.
When I think of an RPG, I think of something that gives me a ton of customization in combat and that requires me to understand the customization system in order to not suck. If you play ME2 on Insane, you'll be ammo-starved and have to know how to use your abilities. I don't get how ME1 can be an RPG but not the second game when it's combat felt a lot deeper than the first game. The first game did have more loot but it didn't really give you more options as far as combat.