IME it went by the posting date: My two 50k bonuses (personal and biz) posted in January 2012 and counted toward 2012 CP.
How long after statement close did bonus points post? I met min spend, and points from min spend have hit my RR account, but the 50K bonus has not, yet.
Also, the companion pass goes by EARNING, not HAVING at one point, right? Meaning, I could spend some of my points before all 110K post, and still qualify for the CP, yes?