Don't know if it's been addressed but this bumper has a completely different bottom bracket than the later bumper, It does not use the frame horn extensions like a later 40 instead a small triangular tab with two holes on the bumper bottom and one on the frame bottom. Also the upper mounting bracket is about 1/2" shorter which changes the mounting locations of all the winch holes.
Generally make sure that you are copying the holes on an original early bumper and realize it will need all the brackets as well to fit correctly. Bottom holes for early bumper:
View attachment 2537757
And this is a later repro 40 bumper and winch on the FJ25 with correct brackets:
View attachment 2537763