According to the OCC representative I spoke with:
When calculating the average daily volume they would like you to use 250 days versus 365.
When calculating balance on debit cards . . . They are talking about stored value cards and not actual ATM/Debit Cards.
Again, according to the rep that I spoke to regarding "retail transactions" she stated to use everything except Bank to Bank transactions. For example she mentioned Fed Funds Sold would not be a retail transaction. However, if you wire loan proceeds to a title company, this would be a retail transaction.
I hope this helps clarify questions for all of you.