Elgin front fender questions.

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I have what I believe to be a '40 ladies Elgin. My question is, what is the proper mounting position of the front fender?
When I got the bike the fender was mounted under the fork. Causing the tire to rub with the substandard mount that was employed.
However, I have seen many other Elgin's with the fender mounted on top of the fork. Which way is correct for this bicycle?
 
If it was meant to be on top, there will be a hole for a screw at about the 11 o'clock and 2 o'clock positions on the fender. There will be corresponding holes in the shoulder of the fork. Also the hole in the fender will be large enough for the steering tube to pass through it.
 
You'd see a great big hole in the middle if it was OTF:

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