I don't see the reasoning behind holding at the fix.
AIM section 6-4-1 3c said:
(1) When the clearance limit is a fix from which an approach begins, commence descent or decent and approach as close as possible to the expect futher clearance time if one has been received, or if one has not been received, as close as possible to the Estimated Time of Arrival (ETA) as calculated from the filed or amended (with ATC) Estimated Time En Route (ETE).
(2) If the clearance limit is not a fix from which an approach begins, leave the clearance limit at the expect furhter clearance time if one has been received, or if none has been received, upon arrival over the clearance limit, and proceed to a fix from which an appraoch begins and commence descent or descnet and approach as close as posible to the estimated time of arrival as calculated from teh filed or amended (with ATC) estimated time en route.
First, the phrase "as close as possible" to me, means that there is some recognized leeway, or slop. How much time is "as close as possible?" It's going to take me 2 minutes to do a 360, which is the smallest maneuver that I can make IMC, so if I arrive less than 2 minutes early, doing a 360 will just move me from early to late. Does it really buy anything?
Secondly, the second paragraph has you travel from your clearance limit to a fix from which you can commence an approach, when your clearance limit is not an IAF. Since ATC has no way of knowing which particular fix you are going to pick before hand, and you have no way of communicating your intentions, how does ATC know when you will be commencing your approach or from which fix? They really don't, all they can do is watch you on the scope (if they have one), and try to clear folks out of your way. They certainly can't be counting on you arriving or departing at a particular time to sequence other folks in and out, when they don't even know what approach you'll be following.
Thirdly, the first paragraph of the section grants additional leeway by stating that pilots are expected "to use good judgment in whatever actions they elect to take" and that it "is virtually impossible to provide regulations and procedures applicable to all possible situations associated with two-way radio failure." The regulations acknowledge that the situation is unusual and fluid.
Fourthly, as several of us have been posting, your ETA as calculated from your ETE is based on your actual takeoff time, not your scheduled or filed takeoff time. How far off are you going to be, anyway?
Put all of that together, and I don't think it makes any sense to hold at the fix, once you get there. I think the idea is to fly your route to your clearance limit, and try the best you can to make your ETA. I don't think the regulation is trying to tell us to hold until some specific time (except when we are in receipt of an EFC time). What I think it is telling us is don't speed up or slow down merely because you have a radio failure. Just fly predictably at a speed to arrive at the IAF "as close as possible" to your ETA, then fly your approach and land. If you read the whole section, I think it leads more to that interpretation, rather than just focusing on the on sentence in question. That's how I read it, anyway.