tunalover,
You can apply a positional tolerance of zero, with no material conditions specified, RFS being the default.
For each of your holes, you get a tolerance zone of MMC to LMC. This controls the outline of your holes at MMC and at LMC, which is what you need. The holes can be off a bit if they are between MMC and LMC. You may have to open up your diameter tolerances a bit to keep things fabricateable.
Why was my first suggestion complicated? You need three datums. Your hole positions and your outside outline dimensions are basic. If your outline is complicated, this dimension strategy gets very simple.
Another strategy is to set the positional tolerance to zero at LMC. If your fastener is a bolt and nut, your MMC diameter is...
MMC = (LMC + BoltDia)/2
For a screw with a positional tolerance of SPT...
MMC = (LMC + ScrewDia + SPT)/2
This is more obvious if you draw it out. I think it is rather complicated. I think my first two ideas are simpler and more logical, and my original idea is better design practice. A large allowable variation in hole diameters means a lot of clearance around the bolt, and not much material under the head.
JHG