Reg. B's definition of "application for credit" is very broad. I'd lean in the direction that what you describe is an application.
1002.2(f) "Application" means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested.
1002.2(q) "Extend credit" and "extension of credit" mean the granting of credit in any form (including, but not limited to, credit granted in addition to any existing credit or credit limit; credit granted pursuant to an open-end credit plan; the refinancing or other renewal of credit, including the issuance of a new credit card in place of an expiring credit card or in substitution for an existing credit card; the consolidation of two or more obligations; or the continuance of existing credit without any special effort to collect at or after maturity).
1002.2(j) "Credit" means the right granted by a creditor to an applicant to defer payment of a debt, incur debt and defer its payment, or purchase property or services and defer payment therefor.
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...gone fishing.