Justification to consider a ‘significant penalty’ and to be excluded from the outflows

Pursuant to article 25(4)(b) of Delegated Regulation (EU) 2015/61,  does the cumulative loss of accrued interest, representing more than 50% of the total contractual interest income upon early withdrawa l of term deposits (specifically those which have been active for more than 50% of their contractual term, have an original maturity longer than 30 days, and a residual maturity exceeding 30 days), constitute sufficient justification to consider this as a ‘significant penalty’ under article 25(4)paragraph (b), with the purpose of discouraging early withdrawal, and therefore allow such retail deposits (for which more  than 50% of contractual term has passed)  to be excluded from the outflows?

The Article 25(4)(b) of the Delegated Regulation (EU) 2015/61 stipulates that  credit institutions may exclude from the calculation of outflows certain clearly circumscribed categories of retail deposits as long as in each and every instance the credit institution rigorously applies the following provisions for the whole category of those deposits, unless an exception can be justified on the basis of circumstances of hardship for the depositor: (a) within 30 calendar days, the depositor is not allowed to withdraw the deposit; or (b) for early withdrawals within 30 calendar days, the depositor has to pay a penalty that includes the loss of interest between the date of withdrawal and the contractual maturity date plus a  material penalty  that does not have to exceed the interest due for the time that elapsed between the date of deposit and the date of withdrawal.