I know there's a required early withdrawal penalty of 7 days minimum interest on the amount withdrawn for time accounts if there's a withdrawal made within the first 6 days of account opening or within 6 days of a prior partial withdrawal and the penalty can't be waived. Here's my question and it may sound crazy. What's the definition of withdrawal? The reason I'm asking is because we have instances where the customer opens a CD and then comes in within the first 6 days and decides to change it into a different term because we're offering a special rate. We close the original CD and open a new one. Because they're reinvesting the funds and not removing them from the bank is that considered a withdrawal? My thought is they entered into a contract and changed their mind within the first 6 days and it seems to me they decided to withdraw the funds and reinvest it in a different fashion.

I would agree with you. I don't think you could waive the penalty in that case.

I also agree.