FreeWithdrawal	Explanation
>10% Bal/ 100% Anv Int	Free Withdrawal without incurring penalties is permitted for the greater of 10% of the balance or the accumulated interest as of the previous contract anniversary.
>10% Bal/ 100% Int	Free Withdrawal without incurring penalties is permitted for the greater of 10% of the balance or the accumulated interest.
1% Per Month Cumulative	Free Withdrawal without incurring penalties is permitted for 1% of the balance each month and is cumulative when not utilized.
10% Bal $5k+ 1 W/D 25%	Free Withdrawal without incurring penalties is permitted for 10% of the balance subject to a $5,000 minimum balance; a one-time withdrawal of 25% is allowed.
10% Bal Cumulative	Free Withdrawal without incurring penalties is permitted for 10% of the balance and is cumulative when not utilized.
10% Bal over $10k+	Free Withdrawal without incurring penalties is permitted for 10% of the balance subject to a $10,000 minimum balance.
10% Bal over $1k+	Free Withdrawal without incurring penalties is permitted for 10% of the balance subject to a $1,000 minimum balance.
10% Bal over $5k+	Free Withdrawal without incurring penalties is permitted for 10% of the balance subject to a $5,000 minimum balance.
10% Bal w/MVA	Free Withdrawal without incurring surrender penalties is permitted for 10% of the balance. However the MVA will still apply.
10% Bal/ 100% Int	Free Withdrawal without incurring penalties is permitted for 10% of the balance or for 100% of the accumulated interest.
10% Bal/100% @ Window	Free Withdrawal without incurring penalties is permitted for 10% of the balance or 100% at the rate guarantee renewal window.
10% Begin CalYr Bal	Free Withdrawal without incurring penalties is permitted for 10% of the balance as of the beginning of the calendar year in which the withdrawal is made.
10% Begin PolYr Bal	Free Withdrawal without incurring penalties is permitted for 10% of the balance as of the beginning of the contract year in which the withdrawal is made.
10% CalYr End Value	Free Withdrawal without incurring penalties is permitted for 10% of the balance as of the end of previous calendar year.
10% CalYr End SVal	Free Withdrawal without incurring penalties is permitted for 10% of the surrender value as of the end of the previous calendar year.
10% CV EaStrategy	Free Withdrawal without penalties except Total Return is permitted for 10% of the cash value. Withdrawals will be taken proportionately from each strategy on a LIFO basis. TRA is applicable on the Total Return Strategy.
10% Init Premium	Free Withdrawal without incurring penalties is permitted for 10% of initial premium.
10% InitPrem Max 40%	Free Withdrawal without incurring penalties is permitted for 10% of the initial premium capped at 40% of the value.
10% MinG SV PrCalYr End	Free Withdrawal without incurring penalties is permitted for 10% of the guaranteed minimum surrender value as of the previous calendar year end.
10% of Premium	Free Withdrawal without incurring penalties is permitted for 10% of the contract premium.
10% of Bal Cum = 20%	Free Withdrawal without incurring penalties is permitted for 10% of the balance and is cumulative to 20% of the value when not utilized.
10% of Bal Cum = 30%	Free Withdrawal without incurring penalties is permitted for 10% of the balance and is cumulative to 30% of the value when not utilized.
10% of Bal Cum = 50%	Free Withdrawal without incurring penalties is permitted for 10% of the balance and is cumulative to 50% of the value when not utilized.
10% of Prev Ratchet	Free Withdrawal without incurring penalties is permitted for 10% of the previous ratchet credited amount.
10% of Balance	Free Withdrawal without incurring penalties is permitted for 10% of the balance and/or accumulated value. Note: All contracts have a minimum balance that must be maintained.
10% Pr Yr Anv Value	Free Withdrawal without incurring penalties is permitted for 10% of the balance as of the previous contract year anniversary.
10% PrAnvBal /100% Window	Free Withdrawal without incurring penalties is permitted for 10% of the balance as of the previous contract year anniversary or 100% of the balance at the contract renewal window.
10% Prem Bal or RMD-Qual	Free Withdrawal without incurring penalties is permitted for 10% of the premiums remaining in the contract or the Required Minimum Distribution for qualified policies.
10% PrYrBal /100Window	Free Withdrawal without incurring penalties is permitted for 10% of the beginning year's balance or 100% of the balance at the guarantee renewal window.
10% Yr1 20% Yr2+	Free Withdrawal without incurring penalties is permitted for 10% of the contract value in year one. Beginning in the second contract year, you may withdraw 20% of the contract value as of the beginning of each contract year.
10%B/Int w/$25k+	Free Withdrawal without incurring penalties is permitted for 10% of the balance or with an account balance of $25,000+ 100% of the accumulated interest.
10%PrYrAnv/ 100% Interest	Free Withdrawal without incurring penalties is permitted for 10% of the balance as of the previous contract year anniversary or 100% of the interest accumulated.
100% Bal over $2k	Free Withdrawal without incurring penalties is permitted for 100% of the balance subject to a $2,000 minimum balance.
100% Each Window	Free Withdrawal without incurring penalties is permitted for 100% of the balance at each contract renewal window.
100% Int Prev Yr	Free Withdrawal without incurring penalties is permitted for 100% of the interest accumulated in the preceding twelve months.
100% Int -Prem Ded	Free Withdrawal without incurring penalties is permitted for 100% of the interest earned after the monthly premium deduction. Withdrawal of interest would limit the amount of benefit accumulation.
100% of Balance	There are no penalties on this contract. Free Withdrawal is permitted anytime.
100% Window 15% Lifetime	Free Withdrawal without incurring penalties is permitted for a lifetime cumulative total of 15% of the premium or 100% at the guarantee renewal window.
100% Yr2+ Prem + Int	Free Withdrawal without incurring penalties is permitted for 100% of the contract renewal premiums plus accumulated interest.
100% Interest	Free Withdrawal without incurring penalties is permitted for 100% of the interest earned.
100%PrYInt 5Yr+Ren	Free Withdrawal without incurring penalties is permitted for 100% of the previous year's interest or 100% may be transferred to another maturity of 5 years or more or after five contract years.
100%PrYrInt/ 100% Window	Free Withdrawal without incurring penalties is permitted for 100% of the interest accumulated in the preceding twelve months or 100% of the value at the contract renewal window.
12% of Init Prem Cum	Free Withdrawal without incurring penalties is permitted for 12% of initial premium and is cumulative when not utilized.
12% of Balance	Free Withdrawal without incurring penalties is permitted for 12% of balance.
14% of Int Earn Cum	Free Withdrawal without incurring penalties is permitted for 14% of credited interest earnings and/or vested value and is cumulative when not utilized.
15% Each Prem Yr1+	Free Withdrawal without incurring penalties is permitted for 15% of each premium one year after its deposit date.
15% of Init Prem Cum	Free Withdrawal without incurring penalties is permitted for 15% of initial premium and is cumulative when not utilized.
15% of Balance	Free Withdrawal without incurring penalties is permitted for 15% of the balance.
15% of Premiums	Free Withdrawal without incurring penalties is permitted for a cumulative maximum equal to 15% of total premiums.
15% PrevCont Anv Value	Free Withdrawal without incurring penalties is permitted for 15% of the balance as of the previous contract anniversary.
15% Yr1 Premium	Free Withdrawal without incurring penalties is permitted only for an amount equal to 15% of the first year premiums for the life of the contract.
18% of Init Prem Cum	Free Withdrawal without incurring penalties is permitted for 18% of initial premium and is cumulative when not utilized.
20% Cal Yr Next w/d 10%	Free Withdrawal without incurring penalties is permitted for 20% of the balance as of the beginning of the calendar year in which the withdrawal is made but the next withdrawal is limited to 10% of the balance.
20% of Int Earned Cum	Free Withdrawal without incurring penalties is permitted for 20% of credited interest earnings and/or vested value and is cumulative when not utilized.
20% Yr1 then 10%	Free Withdrawal without incurring penalties is permitted for 20% in the first contract year and 10% of the balance thereafter.
24% of Init Prem Cum	Free Withdrawal without incurring penalties is permitted for 24% of the initial premium and is cumulative when not utilized.
A55+ 5% Bal A59.5+ 10%	Free Withdrawal without incurring penalties is permitted for 5% of the balance to contract holders age fifty-five only and 10% of the balance to contract holders age fifty-nine and one-half only.
Age 55+ 10% Bal	Free Withdrawal without incurring penalties is permitted for 10% of the balance to contract holders age fifty-five only.
Age 59.5+ 10%/RMD	Free Withdrawal without incurring penalties is permitted for 10% of the balance to contract holders age fifty-nine and one-half only or for the IRS required minimum distribution.
Age 59.5+ 10% Bal	Free Withdrawal without incurring penalties is permitted for 10% of the balance to contract holders age fifty-nine and one-half only after the first contract year.
Age 70+ 10% Bal w/$25k+	Free Withdrawal without incurring penalties is permitted for 10% of the balance to contract holders age seventy only subject to a $25,000 minimum balance.
Current Contr. Yr Interest	Free Withdrawal without incurring penalties is permitted for the interest accrued in the current contract year.
N/A	There are no surrender charges on this contract.
None	No free withdrawal is permitted.
ReqMinD Only	Fee Withdrawal of the IRS required minimum distribution only.
Y3+ 100Int/ 10% PrAnv	Free Withdrawal without incurring penalties is permitted after the third contract year for 10% of the previous ratchet credited amount or for a systematic withdrawal of interest.