Question regarding first wave of regens

When would you say that the first wave of regens appear in the game?

This is what I've noticed during my gameplay:

Let's say that you start the game in Spain, July 2011. The first regens won't spawn until after the first of
January 2012. All regens created afterwards follows the regens date schedule.

Is there anyone that can confirm this pattern?

Or have I been missing out on 6 months of regens?

This is true but if you select add players at new game creation then there will be regens from the start at low league clubs.