This is an unusual situation that I have not seen discussed before. I'm leaning toward believing that the January 2021 distribution does not qualify for the penalty exception because the separation from service that qualified you for the age-55 exception occurred in November 2021 and not before. (I assume that your previous separation from service was not in January 2021.) Certainly at the time of the distribution there was no reason to believe that it qualified for the penalty exception.
