I tend to think that, if your interpretation of the rule had been intended, then that meaning would have been stated more explicitly.
Maybe Hazelnuts, and it may be just me, but I am still stuck with the change to the European rules (and EASA are the more directly affected) - why make that change if they did not mean something by it? They don't usually change long standing wording on a whim. Perhaps FAA just haven't caught up yet - and you know as well as I that there is often a time gap between US and European certification changes.