hmm... I would say "when you lose the freedom to make your own choices, (and I am NOT talking about being good or evil). And when stats becomes an afterthought (which ironicly puts Mass effect in that category for me :S).
when you can not direct the evolvement of the character you choose, it will at best of times be a Diablo kind of thing, and at worst of times pretty much be an actiongame with some stats.
Also I think Pacing has a place in the destinction, for me a True RPG is a slower paced, when you explore, learn about the world, understands it, and becomes a part of it like a single part of a much larger picture, where you start to think based on the input you get from the world. (Horror games tend to share this part)
Actiongames a fast furious, and often very story light... Bioshock for me was no where Near an Rpg, you had no choice (shoot all that moves) nor did it present a world you felt a part of, I had a huge disconnect with my character and the world around him.
Oblivion kinda bridge this gap for me, it felt like a very light RPG, and a very Light Actiongame, mixed with an adventure game, but it still retained most of the above.
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