XX-0.xxx
XXXXXXX
[0000 Xxxxxxxxxxx Xxxxxx NATIONAL LIFE INSURANCE COMPANY
Purchase, New York 10577] OF NEW YORK
A STOCK COMPANY
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5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT WITH BONUS
AND ANNUAL STEP-UP ENDORSEMENT
THIS ENDORSEMENT IS MADE A PART OF THE CONTRACT TO WHICH IT IS ATTACHED AND IS
EFFECTIVE ON THE ISSUE DATE OF THE CONTRACT, UNLESS ANOTHER EFFECTIVE DATE FOR
THIS ENDORSEMENT IS SHOWN BELOW. TO THE EXTENT ANY PROVISIONS CONTAINED IN THIS
ENDORSEMENT ARE CONTRARY TO OR INCONSISTENT WITH THOSE OF THE CONTRACT TO WHICH
IT IS ATTACHED, THE PROVISIONS OF THIS ENDORSEMENT WILL CONTROL.
PLEASE NOTE: THIS ENDORSEMENT CANNOT BE TERMINATED INDEPENDENTLY FROM THE
CONTRACT TO WHICH IT IS ATTACHED.
THE GUARANTEED MINIMUM WITHDRAWAL BENEFIT (GMWB) CAN ONLY BE TAKEN AS A
WITHDRAWAL BENEFIT AND DOES NOT INCREASE THE CONTRACT VALUE. THIS IS AN OPTIONAL
BENEFIT AND THERE IS AN ADDITIONAL COST TO THE SEPARATE ACCOUNT CONTRACT VALUE
FOR THE BENEFIT PROVIDED.
THE FOR LIFE GUARANTEE DOES NOT BECOME EFFECTIVE UNTIL THE LATER OF THE CONTRACT
ANNIVERSARY ON OR IMMEDIATELY FOLLOWING THE OWNER'S (OR OLDEST JOINT OWNER'S)
60TH BIRTHDAY OR THE EFFECTIVE DATE OF THIS ENDORSEMENT. FOR THE FOR LIFE
GUARANTEE TO TAKE EFFECT, THE CONTRACT MUST STILL BE IN FORCE WITH A CONTRACT
VALUE GREATER THAN ZERO AND THE EFFECTIVE DATE OF THE FOR LIFE GUARANTEE MUST BE
BEFORE THE INCOME DATE. IN ADDITION, ON THE EFFECTIVE DATE OF THE FOR LIFE
GUARANTEE, THE GUARANTEED ANNUAL WITHDRAWAL AMOUNT (GAWA) IS RESET.
A PARTIAL WITHDRAWAL IN EXCESS OF THE GREATER OF THE GAWA OR THE REQUIRED
MINIMUM DISTRIBUTION (RMD) MAY HAVE AN ADVERSE EFFECT ON THE GUARANTEED
WITHDRAWAL BALANCE (GWB). THE GWB WILL BE REDUCED BY MORE THAN THE AMOUNT OF THE
PARTIAL WITHDRAWAL IF THE CONTRACT VALUE IMMEDIATELY PRIOR TO THE PARTIAL
WITHDRAWAL IS LESS THAN THE GWB. THE BONUS BASE MAY ALSO BE DECREASED SINCE IT
IS BASED ON THE GWB. ANY WITHDRAWAL IN EXCESS OF THE GREATER OF THE GAWA OR THE
RMD IN ANY CONTRACT YEAR WILL DECREASE THE GAWA.
A BONUS WILL BE APPLIED TO THE GWB AT THE END OF EACH CONTRACT YEAR DURING THE
BONUS PERIOD ONLY IF NO WITHDRAWALS ARE TAKEN DURING THAT CONTRACT YEAR.
WITHDRAWALS UNDER THE GMWB ARE NOT CUMULATIVE. GUARANTEED WITHDRAWALS AVAILABLE
BUT NOT TAKEN DURING ANY GIVEN CONTRACT YEAR CANNOT BE TAKEN AS A GUARANTEED
WITHDRAWAL IN A SUBSEQUENT CONTRACT YEAR.
UPON FULL SURRENDER OF THE CONTRACT, THE GMWB IS TERMINATED WITHOUT VALUE.
SURRENDER OF YOUR CONTRACT WITH A REDUCED OR ZERO CONTRACT VALUE MAY NOT BE
APPROPRIATE IF THE GWB IS POSITIVE.
FOR INFORMATION ON HOW THIS GMWB IS CALCULATED, PLEASE SEE THE ILLUSTRATION ON
PAGE 9.
7532ANY-A
CERTAIN DEFINITIONS AS FOUND IN THE CONTRACT WHICH ARE RELEVANT TO THIS
ENDORSEMENT HAVE BEEN LISTED BELOW FOR INFORMATIONAL PURPOSES.
CONTRACT VALUE. The Contract Value equals the sum of the Separate Account
Contract Value and the Fixed Account Contract Value.
INCOME DATE. The date on which annuity payments are scheduled to begin.
SEPARATE ACCOUNT CONTRACT VALUE. The current value of the amounts allocated to
the Investment Divisions of this Contract.
WITHDRAWAL VALUE. The Contract Value, less any tax payable, minus any applicable
Withdrawal Charges, Annual Contract Maintenance Charges, and charges due under
any optional endorsement to the Contract, adjusted for any applicable Interest
Rate Adjustment.
THE CONTRACT IS AMENDED AS FOLLOWS:
1) The following language is added to the CONTRACT DATA PAGE of the Contract:
"GUARANTEED MINIMUM WITHDRAWAL On a monthly basis, the charge equals [X.XXXX]% of the
BENEFIT (GMWB) CHARGE: Guaranteed Withdrawal Balance (GWB) and is deducted from the
Separate Account Contract Value (i) at the end of each
Contract Month; and (ii) upon termination of the GMWB. Upon
an Owner initiated step-up, the Company reserves the right
to increase the GMWB Charge, subject to a maximum GMWB
Charge, on a monthly basis, of [X.XXXX]%.
The GMWB Charge will be discontinued upon the earlier of the
termination of this benefit or the date on which the
Contract Value equals zero."
2) The following language is added to the DEFINITIONS section of the Contract:
"BONUS PERIOD. The Bonus Period begins on the effective date of this endorsement
and ends on the earlier of (a) the 10th Contract Anniversary following the
effective date of this endorsement, (b) the Contract Anniversary on or
immediately following the Owner's (if Joint Owners, the oldest Owner's) 81st
birthday, or (c) the date on which the Contract Value falls to zero as the
result of a partial withdrawal or deduction of charges.
CONTRACT MONTH. The one-month period beginning on the Issue Date or any Contract
monthly anniversary.
CONTRACT YEAR. The twelve-month period beginning on the Issue Date or any
Contract Anniversary.
GUARANTEED ANNUAL WITHDRAWAL AMOUNT (GAWA). The maximum amount the Owner is
allowed to withdraw each Contract Year, subject to the exception stated in this
endorsement, for the guarantee to remain fully effective.
GUARANTEED WITHDRAWAL BALANCE (GWB). The guaranteed amount available for future
periodic partial withdrawals.
7532ANY-A 2
RECAPTURE CHARGE. For Contracts with a Contract Enhancement, the Recapture
Charge is assessed against certain withdrawals from the Contract Value whenever
a withdrawal is made of the Premium allocated to the Contract Value that has
received a Contract Enhancement, or upon the exercise of the Right to Examine.
REQUIRED MINIMUM DISTRIBUTION (RMD). For certain qualified contracts, the
Required Minimum Distribution is the amount defined by the Internal Revenue Code
and the implementing regulations as the minimum distribution requirement that
applies to this Contract only."
3) The following language is added to the WITHDRAWAL PROVISIONS of the
Contract:
"5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT. The GMWB allows the Owner to
make periodic partial withdrawals, prior to the Income Date, for the longer of:
1) the lifetime of the Owner, or with Joint Owners, the lifetime of the Joint
Owner who dies first if the For Life Guarantee is in effect or 2) until the
total periodic withdrawals equal the GWB at the latest of election, step-up or
application of any bonus plus any subsequent premiums net of any applicable
premium taxes (subject to the $5,000,000.00 limitation discussed below),
regardless of the performance of the Investment Divisions or level of the
Contract Value. The guarantee is fully effective if periodic partial withdrawals
taken within any one Contract Year do not exceed the greater of the GAWA or the
RMD. The GWB will automatically "step up" to the current Contract Value (if
greater than the GWB) on each of the first 10 Contract Anniversaries following
the effective date of this endorsement. Thereafter, the Owner may "step up" the
GWB to the current Contract Value at any time after one year from the prior
step-up, subject to the Guaranteed Withdrawal Balance Step-Up provisions.
Withdrawals under the GMWB are non-cumulative; therefore if the Owner does not
take the GAWA or the RMD in one year, the Owner may not take more than the
greater of the GAWA or the RMD as a guaranteed withdrawal in subsequent years.
The withdrawals made under this endorsement are considered to be the same as any
other partial withdrawals for the purposes of calculating any other values under
the Contract or any other endorsements attached to the Contract.
For purposes of this endorsement, partial withdrawals are considered to be the
entire amount withdrawn from the Contract, including any applicable charges and
adjustments for such withdrawals. The total amount received under the guarantee
may be less than the GWB at election, step-up, or application of any bonus due
to the application of these charges and adjustments.
Any withdrawal less than or equal to the greater of the GAWA or the RMD is
considered a partial withdrawal, not a full withdrawal, even if it is greater
than or equal to the Contract Value.
A partial withdrawal in excess of the Withdrawal Value will be permitted as long
as the total partial withdrawal for the Contract Year does not exceed the
greater of the GAWA or the RMD. A partial withdrawal in excess of the Contract
Value will be permitted as long as the total partial withdrawal for the Contract
Year does not exceed the greater of the GAWA or the RMD. In this case, the
Contract Value will be set to zero and the Contract Value Reduces to Zero
provision will apply.
7532ANY-A 3
If the age of any Owner is incorrectly stated at the time of the election of the
GMWB, on the date the misstatement is discovered the Separate Account Contract
Value will be adjusted by the difference between the GMWB Charges actually paid
and the GMWB Charges that would have been paid assuming the correct age. Future
GMWB Charges will be based on the correct age. If the age at election of the
Owner (if Joint Owners, the oldest Joint Owner) falls outside the allowable age
range, the GMWB will be null and void and all GMWB Charges will be refunded.
ASSESSMENT OF GMWB CHARGE.
The GMWB Charge is as specified above. This charge will be deducted at the end
of each Contract Month on a pro rata basis from the Investment Divisions of the
Separate Account. GMWB Charges in excess of Separate Account Contract Value will
be waived. GMWB Charges result in a redemption of Accumulation Units. The GMWB
Charge will not affect the value of the Accumulation Units. Upon termination of
the GMWB, a pro rata GMWB Charge will be assessed against Your Separate Account
Contract Value for the period since the last monthly GMWB Charge.
GUARANTEED WITHDRAWAL BALANCE.
On the effective date of this endorsement, the GWB is determined as follows and
is subject to a maximum of $5,000,000.00:
1. If elected as of the Issue Date of the Contract, the GWB equals the initial
Premium, net of any applicable premium taxes.
2. If elected after the Issue Date of the Contract, the GWB equals the
Contract Value on the effective date of this endorsement, less any
applicable Recapture Charges that would be assessed on a full withdrawal.
With each subsequent Premium received after this endorsement is effective, the
GWB will be recalculated to equal the GWB prior to the Premium payment plus the
amount of the Premium payment, net of any applicable premium taxes, subject to
the maximum shown above.
With each partial withdrawal, the GWB is reduced. If You choose to withdraw an
amount that exceeds the greater of the GAWA or the RMD during any Contract Year,
the guarantee provided by this endorsement may be reduced to an amount less than
the GWB at election, step-up, or application of any bonus.
Partial withdrawals will affect the GWB as follows:
1. If the partial withdrawal plus all prior partial withdrawals made in the
current Contract Year is less than or equal to the greater of the GAWA or
the RMD, the GWB is equal to the greater of:
a. the GWB prior to the partial withdrawal less the partial withdrawal;
or
b. zero.
2. If the partial withdrawal plus all prior partial withdrawals made in the
current Contract Year exceeds the greater of the GAWA or the RMD, the
excess withdrawal is defined to be the lesser of the total amount of the
current partial withdrawal or the amount by which the cumulative partial
withdrawals for the current Contract Year exceeds the greater of the GAWA
or the RMD, and the GWB is equal to the greater of:
7532ANY-A 4
a. the GWB prior to the partial withdrawal, first reduced dollar for
dollar for any portion of the partial withdrawal not defined as an
excess withdrawal, then reduced in the same proportion that the
Contract Value is reduced for the excess withdrawal; or
b. zero.
GUARANTEED ANNUAL WITHDRAWAL AMOUNT.
On the effective date of this endorsement, the Guaranteed Annual Withdrawal
Amount is equal to 5% of the GWB.
With each subsequent Premium received after the effective date of this
endorsement, the GAWA will be recalculated to equal the GAWA prior to the
Premium payment plus 5% of the subsequent Premium payment, net of any applicable
premium taxes, or 5% of the increase in the GWB, if less.
Partial withdrawals will affect the GAWA as follows:
1. If the partial withdrawal plus all prior partial withdrawals made in the
current Contract Year is less than or equal to the greater of the GAWA or
the RMD and the For Life Guarantee is effective, the GAWA will be
unchanged.
2. If the partial withdrawal plus all prior partial withdrawals made in the
current Contract Year is less than or equal to the greater of the GAWA or
the RMD and the For Life Guarantee is not effective, the GAWA is the lesser
of:
a. the GAWA prior to the partial withdrawal; or
b. the GWB after the partial withdrawal.
3. If the partial withdrawal plus all prior partial withdrawals made in the
current Contract Year exceeds the greater of the GAWA or the RMD and the
For Life Guarantee is effective, the excess withdrawal is defined to be the
lesser of the total amount of the current partial withdrawal or the amount
by which the cumulative partial withdrawals for the current Contract Year
exceeds the greater of the GAWA or the RMD, and the GAWA is reduced in the
same proportion as the Contract Value is reduced for the excess withdrawal.
4. If the partial withdrawal plus all prior partial withdrawals made in the
current Contract Year exceeds the greater of the GAWA or the RMD and the
For Life Guarantee is not effective, the excess withdrawal is defined to be
the lesser of the total amount of the current partial withdrawal or the
amount by which the cumulative partial withdrawals for the current Contract
Year exceeds the greater of the GAWA or the RMD, and the GAWA is the lesser
of:
a. the GAWA prior to the partial withdrawal, reduced in the same
proportion that the Contract Value is reduced for the excess
withdrawal; or
b. the GWB after the partial withdrawal.
GUARANTEED WITHDRAWAL BALANCE BONUS.
A bonus will be applied to the GWB at the end of each Contract Year during the
Bonus Period if no withdrawals are taken during that Contract Year.
At the time the bonus is applied:
1. The GWB equals the GWB prior to the application of the bonus plus 6% of the
bonus base, subject to a maximum of $5,000,000.00.
2. The GAWA is the greater of:
a. 5% of the new GWB; or
b. the GAWA prior to the bonus.
7532ANY-A 5
The bonus base is determined as follows:
1. At election, the bonus base is equal to the GWB.
2. At step-up, (if the GWB increases upon step-up) the bonus base is set equal
to the greater of the GWB following the step-up or the bonus base prior to
the step-up.
3. At the time of a partial withdrawal, if the partial withdrawal plus all
prior partial withdrawals made in the current Contract Year exceeds the
greater of the GAWA or the RMD, the bonus base is set equal to the lesser
of the GWB following the partial withdrawal or the bonus base prior to the
partial withdrawal.
4. Upon any premium payment subsequent to election, the bonus base is
increased by the amount of the premium payment, net of any applicable
premium taxes, subject to a maximum bonus base of $5,000,000.00.
FOR LIFE GUARANTEE.
While the Contract is still in force with a Contract Value greater than zero and
before the Income Date, the For Life Guarantee becomes effective on the later
of:
1. the Contract Anniversary on or immediately following the Owner's (if Joint
Owners, the oldest Owner's) 60th birthday; or
2. the effective date of this endorsement.
At the time the For Life Guarantee becomes effective, the GAWA is reset to equal
5% of the current GWB.
The For Life Guarantee is terminated when this GMWB is terminated or if this
GMWB endorsement is continued by a spousal Beneficiary.
CONTRACT VALUE REDUCES TO ZERO.
If the Contract Value is reduced to zero, all other rights under the Contract
cease (except for the right to change the Beneficiary), no subsequent Premium
payments will be accepted, and all other endorsements are terminated without
value. The Bonus Period is terminated and no further bonuses are applied.
If the For Life Guarantee is effective, the Owner will receive annual payments
of the GAWA until the death of the Owner or the death of any Joint Owner.
If the For Life Guarantee is not effective, the Owner will receive annual
payments of the GAWA until the GWB, if any, is depleted. The last payment will
not exceed the remaining GWB at the time of payment.
Subject to the Company's approval, the Owner may elect to receive payments more
frequently than annually. However, the sum of the payments made during the year
may not exceed the annual payment amount described above.
With each payment, the GWB is reduced by the amount of the payment until the GWB
is depleted.
Upon the death of the Owner or the death of any Joint Owner, the Beneficiary
will receive the scheduled payments until the remaining GWB, if any, is
depleted. No other death benefit will apply.
7532ANY-A 6
GUARANTEED WITHDRAWAL BALANCE STEP-UP.
On each of the first 10 Contract Anniversaries following the effective date of
this endorsement, the GWB will automatically step up to the Contract Value if
the Contract Value is greater than the GWB.
On or after the 11th anniversary of the effective date of this endorsement, the
Owner may elect to step up the GWB. Step-ups may be elected anytime after one
year from the prior step-up. Upon election of a step-up, the Company reserves
the right to prospectively increase the GMWB Charge, subject to the maximum GMWB
Charge indicated in this endorsement. The request will be processed and
effective on the day We receive the request in Good Order.
At the time of step-up:
1. The GWB equals the Contract Value, subject to a maximum of $5,000,000.00.
2. The GAWA is the greater of:
a. 5% of the new GWB; or
b. the GAWA prior to the step-up."
4) The following language is added to the DEATH BENEFIT PROVISIONS of the
Contract:
"Upon the death of the Owner or the death of any Joint Owner, while the Contract
is still in force, the GMWB terminates without value.
Upon continuation of the Contract by a spousal Beneficiary, the spouse may elect
to terminate the GMWB on the Continuation Date and thereafter no GMWB Charge
will be assessed. If the spouse does not make such election on the Continuation
Date, the GMWB will remain in force and may not be subsequently terminated
independently from the Contract to which it is attached.
If the GMWB is continued, the spouse will not be entitled to the For Life
Guarantee. No adjustments will be made to the GWB or the GAWA at the time of
such continuation. Step-ups will continue automatically or as permitted in
accordance with the rules described under the Guaranteed Withdrawal Balance
Step-Up provision. Continuance of automatic step-ups will continue to be based
on the original effective date of this endorsement. Bonuses will continue to
apply in accordance with the rules described in the Guaranteed Withdrawal
Balance Bonus provision. Contract Years and Contract Anniversaries will continue
to be based on the anniversary of the original Contract's Issue Date. The Bonus
Period will continue to be based on the original effective date of this
endorsement or the original Owner's age, as applicable."
5) The following language is added to the INCOME PROVISIONS of the Contract:
"On the Latest Income Date if the For Life Guarantee is in effect, in addition
to the Income Options available under the Contract, the following Income Option
may be elected:
7532ANY-A 7
LIFE INCOME OF THE GAWA. The Owner is entitled to receive payments of a fixed
dollar amount payable during the lifetime of the Owner. The total annual amount
payable under this option will equal the GAWA in effect at the time of election
of this option. This amount will be paid in the frequency (not less than
annually) that the Owner elects. No further annuity payments are payable after
the death of the Owner, and there is no provision for a death benefit payable to
the Beneficiary. Therefore, it is possible for only one annuity payment to be
made under this Income Option if the Owner has an early death.
On the Latest Income Date if the For Life Guarantee is not in effect, in
addition to the Income Options available under the Contract, the following
Income Option may be elected:
SPECIFIED PERIOD INCOME OF THE GAWA. The Owner is entitled to receive payments
of a fixed dollar amount for a stated number of years. The actual number of
years that payments will be made is determined on the calculation date by
dividing the GWB by the GAWA. Upon each payment, the GWB will be reduced by the
payment amount. The total annual amount payable under this option will equal the
GAWA in effect at the time of election of this option, but will not exceed the
remaining GWB. This amount will be paid over the determined number of years in
the frequency (not less than annually) that the Owner elects. If, at the death
of the Owner, payments have been made for less than the stated number of years,
the remaining payments will be made to the Beneficiary. This option may not be
available on certain Qualified Plans."
TERMINATION OF THE GMWB. The GMWB will terminate, a pro rata GMWB Charge will be
assessed against Your Separate Account Contract Value for the period since the
last monthly GMWB Charge, and all benefits under this endorsement will cease on
the earlier of:
1. the date the Owner elects to receive income payments under the Contract;
2. the date of a full surrender;
3. the date upon which the Contract terminates because the Owner or any Joint
Owner dies, unless continued by the spouse;
4. the Continuation Date if the spousal Beneficiary elects to terminate the
GMWB; and
5. the date upon which all obligations for payment under this endorsement have
been satisfied after the Contract has been terminated.
Endorsement effective date (if different from Issue Date of the Contract):
__________________________
SIGNED FOR THE XXXXXXX NATIONAL LIFE
INSURANCE COMPANY OF NEW YORK
XXXXX X XXXXXXX, XX.
PRESIDENT AND CHIEF EXECUTIVE OFFICER
7532ANY-A 8
ILLUSTRATION OF THE CALCULATION OF THE
5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT WITH BONUS AND ANNUAL STEP-UP
These examples are provided to assist you in understanding how the GWB and GAWA
values are computed for this endorsement. The examples only depict limited
circumstances and specific factual assumptions. The results may vary depending
upon the timing or sequence of actions as well as changes in market conditions.
The following examples assume you elect the 5% For Life GMWB with Bonus and
Annual Step-Up when you purchase your Contract and your initial Premium payment
is $100,000. No other optional benefits are elected. Under these circumstances,
your initial GWB is $100,000, your initial GAWA is $5,000, and your initial
bonus base is $100,000.
EXAMPLE 1: WITHDRAWAL EQUAL TO THE GAWA WHEN THE CONTRACT VALUE HAS DECREASED
DUE TO NEGATIVE MARKET PERFORMANCE.
If you withdraw the GAWA ($5,000) and your Contract Value is $80,000 at the time
of withdrawal, then
o Your GWB becomes $95,000, which is your prior GWB ($100,000) minus the
GAWA ($5,000).
o Your GAWA for the next year remains $5,000, because you did not take
more than the GAWA ($5,000).
o Your bonus base remains $100,000 because you did not withdraw more
than the GAWA ($5,000). However, since a withdrawal was taken during
the Contract Year, no bonus will be applied to the GWB at the end of
the Contract Year.
EXAMPLE 2: WITHDRAWAL EXCEEDS THE GREATER OF THE GAWA OR THE RMD WHEN THE
CONTRACT VALUE HAS DECREASED DUE TO NEGATIVE MARKET PERFORMANCE.
If you withdraw $20,000, your GAWA of $5,000 is greater than your RMD, your For
Life Guarantee is effective, and your Contract Value is $80,000 at the time of
withdrawal, then
o The excess withdrawal is the amount by which the partial withdrawal
exceeds the GAWA: $20,000 - $5,000 = $15,000.
o Your GWB is first reduced dollar for dollar by the portion of the
partial withdrawal NOT defined as an excess withdrawal: $100,000 -
($20,000 - $15,000) = $95,000.
o Your GWB is then reduced in the same proportion that your Contract
Value is reduced for the excess withdrawal:
o Your Contract Value, after reduction for the dollar for dollar
portion, is $75,000. The excess withdrawal of $15,000 reduces
your Contract Value by a factor of $15,000/$75,000 = 0.20.
o Your GWB is equal to: $95,000 x (1 - 0.20) = $76,000.
o YOUR NEW GWB IS $76,000.
o Your new GAWA is $4,000, which is your GAWA prior to the withdrawal
reduced by 20%.
o We recalculate your bonus base to equal the lesser of your new GWB
($76,000) or your bonus base prior to the partial withdrawal
($100,000). In this case, your new bonus base becomes $76,000. In
addition, since a withdrawal was taken during the Contract Year, no
bonus will be applied to the GWB at the end of the Contract Year.
As you can see from the examples above, taking a withdrawal that exceeds the
greater of the GAWA or the RMD reduces the Guaranteed Minimum Withdrawal
Benefit.
7532ANY-A 9
