The problem with the create a team was that you had to wipe another team out of existence. Take their spot, more or less.
I could never bring myself to wipe a Big Ten team off of the face of the earth, so I would do it to Temple, who was in the original Big East at the time. Unless I wanted to be an "Independent" at which point I would wipe out UCF? iirc. Eventually I would be invited to join either the ACC or Big East in place of one of their existing teams, who would then become Independent afterwards.