Because a surrender change could be avoided by taking the RMD for an IRA annuity from another of the individual's IRAs (assuming that the individual has such an IRA), it seems inappropriate that FMV of the annuity for RMD purposes would be reduced by the amount of a potential surrender charge. With sufficient funds in the other IRA, all IRA RMDs could be satisfied from that other IRA until the surrender charge for the IRA annuity ages out. I would also expect that the IRA annuity contract would waive surrender charges for RMDs.
RMDs are a federal requirement, so it seems odd that a state authority would have any say in this.
