Yes, that is right!
As for the S402 the biggest difference between the tuned by STI (next most comparable trim level) are the Engine, ECU, Fenders, shocks, springs and rear sway bar in trunk. The S402 also has 2.5L engine and has its own twin scroll turbo specific to it.
I would say the difference is greater between a US Legacy Spec B and JDM Legacy Spec B than an S402 vs a tuned by STI Legacy.
As for the front and rear bumper that is stock for JDM. The US market got the fat bumper version.