TOPIC: Refrigerator GFCI

This is my take on the scenario you described.

A GFCI is designed to protect a person from electrocution.  And they are required at all kitchen counter tops. (Depending on age of building)

A grounded outlet is designed to protect the appliance. Like the refrigerator.
Older appliances can cause the GFCI to trip and therefore clients are likely to call on the home inspector for blame. (Been there)

There is no reason for the refrigerator to be on a GFCI. On a newer appliance it is less likely to trip the GFCI.

In regards to the builder and electrician. I would still call it out and state the potential for a nuisance trip and if the client, builder and electrician do not want to replace with a standard 20 amp grounded receptacle then it would not be my fault if it trips and there $500 worth of imported steaks from Zimboobway spoil!!

I just got off the phone with the head of Boise electrical code enforcement. He said there is some confussion because the new code is that all outlets in the garage are to be on GFCI outlets, no more dedicated circuits for refrigerators, freezers, vacuum, or water softener . I guess since it mentions the dedicated outlet for refrigerators it is getting mixed up.

He did say it is note against code to have a kitchen refrigerator on a GFCI outlet, but not recommended.