Afaik, the out of contract (next season) count and I think Becks mentioned this either earlier in this thread or in another.
Otherwise you'd get a 3*, probably same level draw if you had all OOC players.
But I can't say for certain so useful to confirm.
EDIT: Since I do the Cup Q Manipulation Lite, keeping 11 1st team players with Q raised to what ever I like + the 3 Stooges (declining 1* players on the bench) this is how Cup levels have went. (Looks like I have Level 17 this Season.)
The 4 seasons prior to this I finished 3rd, 3rd, 2nd and 1st the main difference being that previously my wins were shocks (Genius) whereas latterly my losses were shocks (Trolls obviously
). >.<