I did a little googling after I posted that and found the change (for Hershey, at least) to have taken place in late 2008- a lot of complaints popped up in September of that year.
Yes- the FDA has a very specific definition of 'Chocolate' and so Hershey substituted 'Chocolate Candy', 'Chocolatey' and some other similar words in product descriptions where they changed the recipe to less than the FDA's definition.
I had some of the newer Hershey projects that removed the coco butter and put in some type of oil. It was so NASTY I gave it away and I haven't purchased them since.