Dark Star Bank has estimated its average VAR for the previous 60 days to be $35.5 million. DEAR for the previous day was $30.2 million. Under the latest BIS standards, what is the amount of capital required to be held for market risk? Dark Star has $15 million of Tier 1 capital, $37.5 million of Tier 2 capital, and $55 million of Tier 3 capital. Is this amount of capital sufficient? If not, what minimum amount of new capital should be raised? Of what type?