Well I do think a hold is indicated by the wording of FAR 91.185, so the question it seems to me is why is it a requirement to hold when early to the fix. I will venture a guess it is for the situation where another airplane just got on final at the fix in question, perhaps they were late or simply on-time, and you are right on their tail due to being early to the fix. In IMC with no radio (NORDO) you would not know this and it could make for trouble if separation was compromised. There should be a minimum sector altitude on the approach plate to assure terrain clearance for a hold in case you need one. Do a standard hold at that fix until EFC arrives, and then fly the approach. The purpose of all the lost comm procedures is to maintain separation when only a prior clearance instruction exists for the NORDO aircraft.