The exception only applies to COVID related issues.  If you ask some of the investment people, any withdrawals in 2020 are free for the taking.  Then it goes down to the ethical side of the equation.  Why did the client pull the money out?  Did they pull it out because they weren't working and wanted to pay off their mortgage because of the uncertainty?  Or did they pull it out because the next door neighbor bought some real cool jet skis and they wanted to keep pace with the neighbors?  As the old saying goes ------------- let your conscience be your guide.