I think you are reading it wrong. Basically, it seems incomplete. This seems to only reference the case where the Hold is available, and is silent on the case where this is not an option. So, as far as it goes, it seems correct and legal. it falls short in that it doesn't address the legally-mandated remedy when Hold is not available. In fact, it goes so far as to imply that Hold is always available...and we know that that's not true.
It seems completely correct and (likely intentionally) incomplete.
You initially disagree with me, but then proceed to say that the plan is incomplete.
The law/regulation is pretty clear as to what it's required to be in the customer service plan (see post #16). By being incomplete, AA's customer service plan does not meet the requirements of the law/regulation, so I am reading it correctly.