Do internal transfers count as withdrawals for purposes of the Early Removal Fee for the AirPods Max® offer?

Yes. Transfers to any account that is not an eligible account count as withdrawals for purposes of the Early Removal Fee, including internal transfers to another Betterment account such as:

  • an IRA
  • a Cash Reserve account
  • a self-directed investing account
  • a Betterment at Work 401(k) account