The rule was issued as an interim final rule because the Fed felt it was an opportunity to not only get rid of the limits but also to provide savers who may have been affected by the pandemic added flexibility for account access. It would have taken months to go the standard route of proposal, comment period, review of comments, final rule.
We may see a final rule, and I would bet there won't be any definitional changes in it.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8