Mike,

You are absolutely correct, and you have referenced all of the appropriate rules in your post. In a guillotine, the offensive wrestler can lock his hands around the head without an arm after near fall criteria is met (i.e., when 45 degrees is met). Near fall points DO NOT have to be earned to lock the hands without an arm. This is a common misconception among some officials and coaches, as many believe there has to be a two count for near fall before the hands can lock, which is incorrect. As soon as the shoulder of the defensive wrestler hits that 45 degree angle to start near fall, the offensive wrestler may lock his hands around the head without the arm in the guillotine.