Do you mean that you demarcate the turns of the DH into two separate actions?
Yes, I've always danced it that way, right or wrong. My biggest difficulty with the figure is that I have never really sorted out what I'm doing with my R side on step 3. The temptation is to bring it around, as part of the overall 3/8 to R, but I think it probably better to take the LF back into the lock, as you would the RF on a turning lock, with very pronounced CBMP and R side lead. My partner prefers the former approach, and says the lead is clearer, but it makes the hold a bit messy.
"Functionally", I have to disagree with you. 4/5 of the HC is a modified heel turn for man (a heel pull), and really has a completely different feel, apart from the obvious difference in direction. Perhaps we can agree to disagree?