I’ve researched 204.2(c) and I do not believe that there permission is given to waive early withdrawal penalties if a customer decides they’d prefer an IRA over a CD. I do not have an “issue” with this activity, but I always like to do a third check to see if anyone has had experiences that I haven’t.
I am a little “rusty” on my early withdrawal penalty rules, but I believe your interpretation is accurate. Hopefully others will voice an opinion 0n this post.