My reasoning is once I started pulling the Holdfast armor sets out of the free track of the pass they started dropping from my umbral engrams. When I noticed this I started saving my umbrals until I could pull the free Falling Guillotine. I got it today and opened ~25 umbrals without one, obviously the loot pool is still large enough for that to happen, so I was wondering if anybody without the pass could confirm that they dropped a F.G. from Umbral Engrams.
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Once you've obtained both Falling Guillotine [i]and[/i] Cold Denial from the pass then they'll drop from the Umbral lootpool. You'll have to get to level 45 on the pass though.
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Both weapons in the season pass are along the free track so you can get them from Engrams, but not until you've reached rank 45.