FOFreddie - I thought the DTA would be counted as part of Regulatory Capital - but not sure.
I think your $60B is probably going to end up closer than $75. I am in the camp of not needing nearly as much as the bank standards. If they are going to get very far on this before the election - and they better hurry - Calabria needs to issue the Cap Rule now and do his fine tuning during the post comment period - I think the post comment period will take them at least 4 months to digest and address and this could take us to the end of September by the time they issue this at the end of March as he has indicated.