Sure, what you say is true. But you know as well as I that insurance companies are evil and lawyers are the gatekeepers of Hell. In a case of a serious accident, say one that includes a death, you know that the lawyers for Toyota, ETrailer, Curt, etc. are going to twist and backstab everyone to get their client out of paying big money.
Curt's instructions specifically state "Do not exceed vehicle's manufacturer's recommended towing capacity". One can interpret this in a couple of ways. But since it's designed for the 4 pintle holes, they must mean the tow capacity of the bumper/cross member. So as long as Toyota USA publishes the maximum tow capacity for those attachment points, and you stay below them, then you're good to go. Toyota USA never published them? SNIP
Actually, Toyota did publish what the 80 series tow limits are for US market versions, right in the manual, as well as stating what should not be used.
"Without towing package, 3500 lbs
With towing package, 5000 lbs"
Combined gross combination weight:
"Without towing package, 10025 lbs
With towing package, 11525 lbs"
Max tongue weight:
"Without towing package, 350 lbs
With towing package, 500 lbs"
"Hitches
* Use only a weight carrying hitch designed for the total trailer weight. Toyota does not recommend using a weight distribution (load carrying) hitch.
* The hitch must be bolted securely to the vehicle's frame and installed according to the hitch manufacturer's instructions.
* The hitch ball and king pin must have a light coat of grease.
* Toyota recommends removing the hitch when not in use...
NOTICE
Do not use an axle-mounting hitch as it may cause damage to the axle housing, wheel bearings, wheels, and/or tires."
One additional caveat...
"If the trailer weight exceeds 1000 lbs, trailer brakes are required."
None of this rules out the pintle attached in the usual place that Toyota provides, assuming you're within those limits. I think I did just discover a good argument to use with my finance director to go ahead and upgrade to a braked axle on our M101 CDN, though. The requirement for brakes when towing over a 1000 lbs is what will probably cause grief more often than any other factor by the looks of things.