The new TSM Chapter 3 says to sign waiting and loading restrictions as normal (with plates and lines) in both bus and mandatory cycle lanes, which I’m pretty sure means making a normal waiting & loading TRO. (Or it could be combined with an order making the cycle lane as well, in order to achieve different exemptions from the somewhat strange set in TSRGD.)

I agree with you that you wouldn’t get very far trying to enforce under CPE if there wasn’t a waiting/loading order and certainly not if there were no yellow lines, given what TSM3 says.