My interpretation of the permanent exceptive relief is that does apply to all rollovers, etc. because FinCEN broadened the language describing the applicability of the exception in the last update and indicated that the most recent guidance supersedes the previous ones. The two previous extensions did have language that arguably limited the exception to automated events, whereas this guidance does not. The material part of the guidance, the first sentence in the second paragraph of the "Conclusion" section, does not include anything suggesting the exception applies only to automated rollovers.

Thank you Pat Patriot Act. Anyone else want to opine?

I agree. Go to the definition of CD or Certificate of Deposit in the ruling to see what's included. No early or partial withdrawals without penalty and no additions allowed during the term. That's it.

How is everyone handling this now? Are you still obtaining the form when they add or remove funds during the grace period?