221(g) Administrative Processing: Is this a "refusal/denial?"

Would you answer yes to the question about previous refusals if you were given a 221(g) which was approved after AP without having to make another application?

There appears to be conflicting information on Government websites.

The American Embassy in Japan https://jp.usembassy.gov/visas/visa-waiver-program/frequently-asked-questions-esta/ :

I previously applied for a F-1 visa and the application was pending additional documents. I received a notice (221g letter) from the consular officer which said my application is refused. Now I want to go to the U.S for sightseeing. How should I answer the ESTA question “Have you ever been denied a U.S. visa or en...

If your visa application has been refused under section 221(g) of the INA for any reason, you should mark “Yes” for question F on the ESTA application form. A 221(g) refusal will NOT result in an automatic refusal of ESTA. Even if you get a visa after a 221(g) refusal, please continue to answer “Yes” to question on all future ESTA applications.

The American Embassy, Germany https://de.usembassy.gov/visas/esta-wvp-faqs/

My visa application is still pending (in 221g status). Can I travel to the U.S. under the Visa Waiver Program (ESTA) before a final decision has been made?

No. Your current application must be resolved before you would become eligible to apply for the Visa Waiver Program. If you apply for an ESTA clearance while your current application is still pending, you must answer “yes” when asked whether you have ever had a visa application denied. Failure to respond truthfully to the ESTA questions can pose additional problems for future travel to the United States. Once your application has been resolved, you should then answer either “yes” or “no” when asked whether you have ever had a visa application denied based on the final decision of your visa application. Applications which have expired (abandoned cases where more than 1 year has passed from the time of initial application) are considered denials for the purposes of the Visa Waiver Program. Therefore, you must answer “yes” when asked whether you have ever had a visa application denied when applying for an ESTA clearance.

From the Department of State https://fam.state.gov/fam/09FAM/09FAM040310.html

(2) (U) 221(g) Refusal Letter: For an INA 221(g) NIV refusal, posts may draft the refusal letter in the manner they deem appropriate and without Departmental approval. However, the letter must: (a) (U) Explicitly state the provision of the law under which the visa is refused; (b) (U) Not state that the denial is “pending”, “temporary”, or “interim” or that the case is suspended, although it may reference further administrative processing of the case; (c) (U) Neither encourage nor discourage the applicant from reapplying; and (d) (U) Include the following language: Please be advised that for U.S. visa purposes, including ESTA (the ESTA website), this decision constitutes a denial of a visa.

The Embassy in Germany seems to be the most clear but it seems to contradict the other two. "Legal opinion" on the internet seems to be conflicted about this too.