Maybe this is the 'Jeppy' letting you down, but that isn't what my Aerad says (albeit a tiny bit out of date, as I don't keep the current one in my study).
If approaching the hold, you will hold until ETA plus ten, or EAT. No difficulty there, then.
If in the hold already, hold until ETA plus ten or last communication with ATC plus ten, whichever is later, or EAT.
Generic comms failure procedures assume the hold is overhead an airfield beacon, and I would always take all mentions of ETAs as relating to the ETA for the holding fix, especially bearing in mind that EATs apply to leaving the hold.
In a real lost comms situation, if the ground kit has gone, it'll be every man for himself, and things like flying .5nm displaced and two hundred feet high might help to save your life.