[frei]

My point wasn't about withdrawal ordering. I'm not saying you can't withdraw the direct contributions first without penalty.

I'm saying, the law doesn't care that you left the part you over contributed uninvested, and that it was some other money in the account that grew.

I'm saying, to avoid penalty, you have to withdraw (direct contributions first) equal to [excess * (current value/value at date of excess contribution)].

This amount could be higher or lower than what you contributed, depending on how the existing Roth IRA investments in the account changed in value between the time of excess contribution and the withdrawal.