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I don't have authority at hand, but I think "time of the pitch" is considered to be when the pitcher first makes a motion associated with his delivery.
Several other thoughts, however.
A fielder in foul territory does not result in an illegal pitch (or, with runners on, a balk). It is, instead, a "don't do that," as we say. Under OBR 5.02, there is no specified penalty for not being on fair territory; the balk penalty[indented, under (a)] applies only to the catcher.
Nothing in the pitching infraction rule (6.02) talks about fielders' positioning. Likewise, the definition of "illegal pitch" does not include a fielder's position.
An illegal pitch with runners on base is a balk.
Lastly, don't be OOO.
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