I think 5.2.2 is only for carrying the firearm in the holster, not during the make ready. If 5.2.2 applied during make ready, you would not be able to load the handgun since it also requires a empty magazine well.
First, I'm not trying to argue anything. my give a hoot meter is pegged on E. The result is the same (confused RO, but no penalty). so I haven't pulled the thread through the rule book. But 5.22 talks about carrying an unloaded gun in the holster. Once we've loaded it, 8.1 (and 10.5.11) come in to play. I don't see the words MR making a distinction. Splitting pointless hairs since there's no penalty.
-rvb