Sorry, this bit is nonsensical: "15,000 DA's paying $1,200 a year is $18M. I think that fits better than the figures your scenario would generate, which leads me to conclude you are incorrect."
...as we would only be accruing for new DA's under your explanation.
(strike that piece of evidence).
Question still stands though.
itsa figures for oct to dec 2011, page-21
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