I agree with ApothiX on this one, in the sense that I prefer packing the opening brace at the END of the leading line. HOWEVER, I agree that both are perfectly valid, and you will find most scripters are 50/50 split as to which is better. As a result I think both should be allowed as valid in the guidelines above.
Edit:
I spoke with Skyld and this issue is now changed. See above (Section 2.3) for the new proposal. As it currently stands, I am agreeing with everything proposed, so Skyld currently has my endorsement
.