It's not exactly based off the received date or the date on the email. It actually follows a "ChangedDate" thats internal and gets updated based on various actions against the email.
There's another optimization I'm thinking of but I don't remember if we implemented it. Keeping the top/last ~50 items in the folder on primary. Though it's very likely the first scenario given the size you indicated.
Matt Petty
Senior Software Developer
SmarterTools Inc.
www.smartertools.com