OSC 230.4(b)(6)(ii) Early withdrawal penalties
3. Relation to rules for IRAs or similar plans. Penalties imposed by the Internal Revenue Code for certain withdrawals from IRAs or similar pension or savings plans are not early withdrawal penalties for purposes of this regulation.
So, this would not be considered when advertising.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com