In the spirit of the term (i.e., outside its technical definition), definitely yes.
Technically "OC" stands for "Overclocking" or running the component at a faster clock than its rating. So, technically in that narrow definition of OC, no.
However, extending the definition a fraction to include reducing latency, i.e. accesssing memory 1 or more ticks before its rated time (i.e., faster than the rated clocking), then yes. So there is an argument for technically it is "OC".
How's that for a non-answer?
Mike
PS: IMO... yes.