I am not sure exactly what you mean by "replicate Embassy's Interoperable solution".
Despite that, the answer to your question is "No". The architecture and subsequent implementation details are more complex than that. The topic has already been covered in detail in previous posts.
An interoperable TPM driver does not replace the functionality provided by the Wave CSP. However, an interoperable TPM driver included with the OS may be thought of as the first step toward the subsumation of certain functionalities currently provided by Wave products, as alluded to by SKS.
I can not think of any reason why MSFT would not start building on top of their interoperable TBS layer, especially for a proprietary (and controlled) system like XBox360.