That cannot be right.
In my first full game, I was playing Xerxes as Rome, Spain and America. On
turn 1 of the Modern Era, I had a settlement limit of 30:
On top of the 19 you claim Xerxes should have, I'm counting El Escorial to get to 20, then attributes gets me to 22. For the remaining 8, I can only think of 2 from Rome, 2 from the Fealty legacy option (taken in Exploration), 1 from Spain... and that leaves another 3 still. I suspect, but do not know for certain, that the last 3 come from Xerxes's bonus stacking throughout a game, meaning it's 1+2+3=6 bonus for the Modern Era.
(note: no mementos used)