I'd say that on 545 rims 36 spokes will be unneccessary. FYI I'm running a 32/32 3x set of A23 rims to Ultegra hubs at 260 and I have a slight untrue in the rear due to hitting a big pothole a few weeks ago that noone in the paceline pointed out
! They've been a year and 3-4000km so far without a single problem.
With a more gutsy rim like the 545, a higher spoke count would be overkill unless that's what you're after. Also FYI I am looking to hit 240 in the coming months and I've ordered a set of Kinlin 279 rims laced to DA in 28/32. It's my last spend on the roadie before I devote more funds to my track bike addiction.