Mike,
We’re getting into a bit of a fuzzy region here. The requirement is to descend to the altitude depicted on the plate or assigned by ATC prior to reaching the ILS FAF. Good flying protocol (especially in a fast and slippery airplane like the Cirrus) suggests that it’s wise to be at the glide slope intercept altitude and properly configured for the approach no more than one nautical mile outside the ILS FAF (GS intercept.) Properly configured may mean 50% or 0% flaps depending on pilot preference, so don’t interpret my remark to mean that there’s only one correct way to configure the aircraft. The pilot’s attention should be focused on glideslope intercept, crosschecking altitude at the LOM/NDB/OM or whatever fix constitutes the localizer FAF, and setting power as desired.
From a legal perspective, I believe what you are suggesting IS legal, although it seems unnecessarily involved to me.
Regards,
-Ryan