Locked hands interpretation

[CoachH]

I would like to get clarification from experienced referees on a situation that had the referees divided at a recent midle school tournament:

In the advantage position, the top wrestler locks his hands around one arm and the head of the bottom wrestler. This lock is ABOVE the shoulder of the bottom wrestler.

Is this locked hands?

I believe that it is not and that it becomes locked hands only when the lock falls below the shoulder. I would appreciate any clarification and comments.

Thanks,

Coach H