I think Gotham Gator point is that some of that contact may not be meant for the face. For example, Alex Ring holds up an opponent from behind and the opponent swings his arm back to grab Ring's shoulder (who he doesn't know its Ring) and push off of him to create space, seems fine.A player being held that happens to hit the face while swinging his arms is definitely a card. The hold is a foul if noticed, but any hands to the face is a red card.
Maxi Moralez holds an opponent from behind and the opponent swings his arm back to grab Maxi's shoulder (who he doesn't know its Maxi) and push off of him, but because Maxi is 5'2" he catches him in the chin. Now all of a sudden that's a red card.
Or the above contact with Ring, and Ring happens to lower his head for one reason or the other and gets caught in the face, now its a red.