12 points is a lot. I wouldn't be shocked if none of those four teams mentioned scored higher than about 35 points but Everton would still then have to get nearly 50 to survive, and so far we've got 7 points from 9 having played Fulham, Wolves, Bournemouth and Luton at home and Sheffield Utd away.
It is a maximum suggested punishment and I'll be surprised if the actual punishment got anywhere near that but for the Premier League to have the gall to call for that now after telling Leeds and Burnley to shut up in 2022 when they complained about our accounts, and having signed off on all of our paltry business since, and having done nothing about City's 100+ alleged breaches, etc etc, is quite rich to say the least.