Thank you for detailed response. You are right, it's not a rollover, rather a "transfer". The risk-averse client had three IRAs, each invested in a 5-yr CD when rates were minimal but some he locked in 3%. Breaking the CD has a minimal bank penalty that is waived if it's a senior's IRA. Now that CD rates are better, it makes sense to transfer to a brokerage that offers higher CD returns than our small town banks, and simpler for his heirs. (These are not US treasuries that are already sheltered from state tax.) I think it was OK for him to sit out the lean lower yields for the sake of safety. All three banks were super-easy to deal with, they made out checks payable to Vanguard FBO Client, and he mailed them to Vanguard, so not too much trouble on his part. Sometimes brokers are not fond of CD investments that pay little in commissions.