"Also be careful if the distribution was originally coded as an early distribution. No penalty for the second distribution."

Huh. Let's clarify.

The 2020 distribution(s) that qualify, even if the issuer marked them as Early, are all not subject to penalty as long as they met the covid requirement for disaster.

If you are describing the second reportable amount from one distribution reported over three years for taxability, there was not any penalty at all. Or, it didn't even qualify in the first place? Because there is no "no penalty for the second distribution" as stated.

As usual, facts and circumstances matter. I'm simply reviewing some basics of that provision. That provision, if followed, means no penalty ever.