No, that wasn't the issue at all. The issue was whether an OM is required to identify the FAF on an ILS, and it is not, since by definition the FAF on an ILS is glideslope intercept at the published altitude, not the OM. I provided glossary references above. The OM serves only as a check altitude for the glideslope, for the purpose of identifying a false glideslope. However, a false glideslope will not be received if the intercept occurs from below, at the published altitude.
I do not argue that false glideslopes aren't dangerous, and I encourage people to monitor their position and descent rate as well to help eliminate that problem. But that wasn't the question being raised by AggieMike.
Also see c130flyr's reference.