Starting a Rash Charge on top of friendly units

Imagine a scenario where a CP unit moves first and then follows up with a 2nd activation charge. In the first activation the CP ends on top of friendly S and T units. It then announces a 2nd activation charge and moves off the friendly S and T units and contacts the enemy unit. Does starting the charge on top of the friendly units constitute penetrating them by the CP and thus fulfilling the requirements of a Rash Charge/Maneuvered Charge. We thought yes but we were completely certain.

My first thought was yes. But surely S or T should be moved back on the first (non-charge) move? So the CP are not starting the second charge phase on top of friendlies? No need for Rash or Maneuvered charge.

In Impetus 1, interpenetrated units were not displaced until the moving unit had completed its activation. We have been playing Impetus 2 in the same manner. So the S and T would not be displaced after the 1st move.