Accessing your SIPP: When can you access a SIPP?

Understanding when you can access your SIPP

The rules governing when you can first access your SIPP are defined by UK government legislation and apply consistently across all pension providers, although some schemes may have additional restrictions written into their own specific terms.

What is the Normal Minimum Pension Age (NMPA)?

The Normal Minimum Pension Age is the earliest age at which most people can access their pension benefits. This minimum age is currently set at 55, but that’s set to rise to age 57 from 6th April 2028.

This age increase will affect almost everyone who hasn’t reached the Normal Minimum Pension Age yet, except for people with protected pension ages from previous scheme rules or those who happen to turn 55 before the new minimum comes into effect.

If you're currently 53 or 54, then you might reach the age of 55 before the change takes effect in 2028, allowing you to access your pension at 55 rather than waiting until 57. However, you would need to start drawing down from your pension before the 6th April 2028 change, otherwise you’d still need to wait until you’re 57. Most people planning retirement in their mid-50s should factor in the higher age 57 requirement, adjusting their financial planning accordingly to bridge any income gap that might arise due to this delayed access.  

Can I access my SIPP early?

Early access before the Normal Minimum Pension Age is usually only permitted in exceptional circumstances, such as if you have a serious ill health condition that reduces your life expectancy to less than 12 months.

Some SIPP providers might have slightly more lenient terms where you can access your pension earlier if you’re suffering from ill health that prevents you from working but isn’t terminal.

It’s important to note that there are some known pension scams that claim they can help you to access your SIPP earlier than the NMPA even if you aren’t suffering from ill health. These scams usually involve transferring your pension in order to enable "early access," but doing this would breach HMRC rules and trigger serious financial penalties.

Accessing your pension early without proof of ill health or serious ill health would result in:

• A 55% “unauthorised payment charge” from HMRC
• An additional 40% unauthorised payment surcharge if the withdrawal is over 25% of the fund’s value
• The complete loss of the tax-free status for your pension pot

When these charges are combined they can amount to more than 100% of the amount withdrawn, destroying your retirement savings. That’s why it’s essential that you always verify any firm that’s suggesting early access through the FCA register and seek independent regulated advice before considering any pension transfer.

What does 'crystallising' your SIPP mean?

Crystallisation is the process of designating all or part of your SIPP to provide retirement benefits, converting uncrystallised funds (which you haven't started accessing) into crystallised funds (which are designated for providing benefits).

When you crystallise your SIPP:

• You can take up to 25% as tax-free cash (known as the Pension Commencement Lump Sum)
• The remaining 75% becomes available for taxable withdrawals
• The tax-free cash is tested against the Lump Sum Allowance (which is currently £268,275)
• Further crystallisation events will be tested against remaining allowances.

You don't have to crystallise your entire SIPP at once. Partial crystallisation allows you to take smaller amounts as needed, potentially managing tax more efficiently by spreading withdrawals across multiple tax years.

For example, if you had a £200,000 SIPP, you might decide to crystallise £40,000, taking £10,000 tax-free and moving £30,000 to drawdown. The other £160,000 in the SIPP remains uncrystallised for future access, giving you control over timing and tax management.

The Money Purchase Annual Allowance (MPAA)

It’s important to have a firm understanding of the MPAA, because triggering it would restrict your ability to make future pension contributions, permanently limiting the amount that you can contribute tax-free to just £10,000 a year.

What is the MPAA?

The Money Purchase Annual Allowance reduces your Annual Allowance from £60,000 to £10,000 once you start taking flexible pension benefits. This restriction prevents people from withdrawing pension funds while simultaneously making large contributions to receive additional tax relief.

The £10,000 MPAA limit applies only to money purchase (Defined Contribution) pensions, but that means it applies to all SIPPs.

Once the MPAA is triggered the £10,000 limit  is permanent and applies for the rest of your life, which is why it’s so important that you understand exactly what actions could trigger it before making any SIPP withdrawals.

What triggers the MPAA?

Doing any of the following will trigger the MPAA:

• Taking taxable income from flexi-access drawdown
• Taking an Uncrystallised Funds Pension Lump Sum (UFPLS)
• Receiving income from a fixed term annuity
• Receiving flexi-access drawdown payments from a pension you've transferred to.

On the other hand, doing the following won’t trigger the MPAA:

• Taking only your 25% tax-free Pension Commencement Lump Sum
• Buying a lifetime annuity
• Taking small lump sums under the small pots rule (£10,000 or less per pot)
• Serious ill-health lump sums.

The key distinction between what triggers the MPAA and what doesn’t is whether or not you're taking flexible benefits that could potentially be recycled back into pensions. Tax-free cash alone doesn't trigger the MPAA because you can't recycle it for additional tax relief, but any taxable flexible withdrawals do trigger it.

How can you avoid triggering the MPAA prematurely?

There are three different strategies you can employ if you want to ensure you don’t trigger the MPAA:

1. Take only tax-free cash initially:   If you only need the 25% tax-free element, then you can crystallise that part of your SIPP and take the Pension Commencement Lump Sum without taking taxable income . This leaves your annual allowance at £60,000 for future contributions.
2. Use the small pots rule: If you have multiple small pension pots each worth £10,000 or less, you can take them as lump sums (25% tax-free, 75% taxable) without triggering the MPAA, provided each pot is with a different provider. However, this small pots rule is limited to three personal pensions, although there usually isn’t a limit on the number of workplace pensions provided each one is worth less than £10,000.
3. Delay flexible access: The third approach is to continue making pension contributions up to the standard £60,000 Annual Allowance until you no longer need to contribute, then switch to flexible access once your contributions stop.

Actions That Trigger the MPAA

Taking Your Tax-Free Cash (Pension Commencement Lump Sum)

Your Pension Commencement Lump Sum (PCLS) provides valuable tax-free capital at the start of your retirement.

How much can I take tax-free?

You can take up to 25% of your SIPP as tax-free cash, subject to the Lump Sum Allowance of £268,275 introduced when the Lifetime Allowance was abolished in April 2024.

For most people, 25% of their total pension wealth will fall below this £268,275 cap, meaning they can take a full quarter of their pension pot tax-free.

If 25% of your pension does exceed this £268,275 maximum, then you can only take £268,275 tax-free but anything above that will be taxed as income at your marginal rate.

Some people with very large pensions (specifically, those with a pension value of £1.25 million or more) may still have protection from previous lifetime allowance rules from 2014 or 2016, which could allow them to take more tax-free cash. However, those individual protections apply to a very small number of pension holders, and in most cases the £268,275 Lump Sum Allowance is the figure you’ll work towards.

Should I take it all at once or phase withdrawals?

Taking your entire 25% entitlement upfront can give you immediate access to a significant amount of capital, which might be useful for specific purposes like paying off mortgages, funding major purchases, or investing outside pensions.

Advantages of taking it all at once:

• Immediate access to your full tax-free entitlement
• Certainty about your tax-free amount
• Simpler planning with one single transaction

Disadvantages of taking it all at once:

• Such a large sum might not actually be needed immediately
• There’s the potential for poor spending decisions when you receive such a substantial lump sum in one go
• It may trigger higher tax bands if you need additional income beyond the tax-free element.

On the other hand, taking your 25% tax-free allowance gradually over time allows you to crystallise portions of your SIPP as needed and take 25% of each portion tax-free.

Advantages of a phased approach:

• Better tax management by spreading taxable elements across multiple years
• Maintains more funds invested for potential growth
• Provides flexibility to adjust based on changing needs
• Can avoid triggering MPAA until you actually need taxable income.

Disadvantages of a phased approach:

• More complex administration with multiple crystallisation events
• Requires ongoing planning and decision-making
• May not suit people needing a lot of funds immediately.

How the new rules replaced the Lifetime Allowance (LTA)

The Lifetime Allowance was abolished in April 2024, replaced by three new allowances that serve different purposes:

• Lump Sum Allowance (LSA): The Lump Sum Allowance is £268,275 for most people, which is the maximum tax-free cash you can withdraw across all your pensions throughout your lifetime. Once you hit that limit, any further lump sums you withdraw are taxed as income.
• Lump Sum and Death Benefit Allowance (LSDBA): In addition to the Lump Sum Allowance, there’s a limit of £1,073,100 covering both lifetime lump sums and death benefits, preventing people from taking substantial tax-free amounts during their lifetime and then passing further tax-free amounts on to their beneficiaries when they die.
• Overseas Transfer Allowance (OTA): £1,073,100 is also the maximum for transferring pensions to overseas schemes before tax charges apply.

These allowances replaced the single Lifetime Allowance that previously capped total tax-relieved pension saving at £1,073,100, providing more targeted limits on specific types of pension access rather than on total pension wealth.

Common tax-free cash mistakes

Some of the most common mistakes SIPP holders can make when it comes to tax-free pension withdrawals include:

• Recycling withdrawals: Taking tax-free cash then immediately contributing it back to a pension in order to receive additional tax relief is prohibited. HMRC's recycling rules impose tax charges if you increase pension contributions significantly after taking tax-free cash.
• Accidentally exceeding the LSA: Each tax-free withdrawal reduces your remaining Lump Sum Allowance. Tracking the total of your lump sum withdrawals carefully can help you prevent accidentally exceeding your allowance and facing unexpected tax charges.
• Invalidating individual protection: While this applies to a fairly small number of people, if you had enhanced individual protection under previous pension rules, there are some things that could invalidate this protection. You should seek advice before making withdrawals if you have any form of lifetime allowance protection.

Comparing PCLS Options

Options for Accessing Your SIPP Funds

The pension freedoms that were introduced in 2015 give you a few options when it comes to how you access your SIPP, each of which comes with distinct advantages, risks, and tax implications.

Flexi-Access Drawdown

With flexi-access drawdown you move some or all of your SIPP into drawdown, designating funds to provide retirement income while keeping the money invested. You retain full control over withdrawal amounts and timing, taking income as needed while your remaining funds continue to grow (or fall) in line with the performance of your investments.

Benefits:

• You have complete flexibility over withdrawal amounts and timing
• Your funds remain invested with growth potential
• You can adjust income based on changing needs
• Death benefits can pass flexibly to beneficiaries
• You can maintain investment control throughout retirement.

Risks:

• Taking any taxable income from the flexi-access drawdown immediately triggers the £10,000 MPAA, limiting future pension contributions
• Investment values will fluctuate with market conditions
• There’s a sequence of returns risk, where poor performance early in retirement could permanently undermine the value of your portfolio
• This approach requires ongoing investment decisions and portfolio management
• There’s the risk of taking too much too quickly, depleting funds prematurely
• There’s no guaranteed income if markets perform poorly.

Uncrystallised Funds Pension Lump Sum (UFPLS)

With UFPLS, you take lump sums directly from your uncrystallised SIPP without formally moving funds into drawdown. Each withdrawal consists of 25% tax-free cash and 75% taxable income, providing simple access without requiring separate crystallisation events.

Benefits:

• UPFLS offers a fairly simple, straightforward approach that requires no formal drawdown arrangement
• This approach offers you flexible ad-hoc withdrawals when needed
• Could be a suitable approach for smaller pension pots or irregular income needs
• There’s no ongoing investment management requirements
• Works well for taking occasional lump sums.

Risks:

• Triggers MPAA immediately with the first taxable payment
• Each withdrawal reduces the invested balance, limiting growth potential
• You might end up overpaying tax through emergency codes, requiring reclaims
• UPFSL is less tax-efficient than phased approaches for larger withdrawals.

Annuity Purchase

With an annuity, you exchange some or all of your SIPP for guaranteed income payments from an insurance company, either for life (lifetime annuity) or a fixed period (fixed-term annuity).

Benefits:

• Guaranteed income regardless of investment performance or life expectancy
• Removes longevity risk since payments can continue for life (if you opt for a lifetime annuity)
• There’s no ongoing investment decisions or management required
• The guaranteed income makes budgeting easier
• You’ll be protected from market volatility.

Risks:  

• Your decision to purchase an annuity is permanent and you can’t change your mind after you buy it
• Triggers MPAA immediately with the first taxable payment
• Inflation erodes your annuity’s purchasing power unless you specifically purchase an escalating annuity, which increases with inflation
• There’s no flexibility to increase or decrease your income
• Some annuities have very limited death benefits, although this does depend on the type of annuity you choose
• If you don’t live as long as expected you might not receive the full value of your pension.

Combining options

Many people use hybrid approaches, combining different access methods to balance security, flexibility, and tax efficiency.

Common combinations:

• Annuity for essential expenses (housing, utilities, food) plus drawdown for discretionary spending
• A phased approach that takes some funds as an annuity immediately, while keeping the remainder in drawdown
• UFPLS for irregular large expenses while maintaining steady drawdown income.

HSIPP Withdrawal Options Compared

How SIPP Withdrawals Are Taxed

Understanding the tax treatment of SIPP withdrawals can help you plan effectively and avoid unexpected tax bills.

How income is taxed through PAYE

Pension withdrawals are taxed as earned income, with your SIPP provider operating PAYE and deducting tax before paying you. The process is similar to employment taxation, although you won’t have to pay National Insurance on any pension withdrawals.

Your first pension withdrawal often triggers an emergency tax code (typically Month 1 basis), which assumes you'll receive similar amounts every month for the entire tax year. This often means you’ll overpay tax initially, which you’ll then have to reclaim through HMRC.

Interaction with other income

SIPP withdrawals are combined with all your other income for tax purposes, including employment or self-employment income, State Pension, other private pensions, rental income from property, and investment income.

Your total income determines your tax band and marginal rate, making withdrawal planning crucial for tax efficiency.

National Insurance and SIPP withdrawals

You don’t have to pay National Insurance contributions on pension income, regardless of your age or employment status.

If you’re still working or are self-employed, National Insurance will still apply on those earnings, but not on pension withdrawals. This makes pension access while working more tax-efficient.

Example SIPP Withdrawal Tax Scenarios

Planning Withdrawals and Managing Risk

By properly planning pension withdrawals you can ensure you have adequate income in retirement while preserving part of the capital for later years.

When should I start withdrawing?

There are a number of factors to take into account when you’re deciding when to start withdrawing funds from your pension, including your life expectancy and health, your other sources of income (State Pension, employment, rental income), your cash flow needs and major expenditure timing.

Many people access their SIPPs before State Pension age, but this strategy requires careful planning because if you need larger withdrawals from your SIPP in the early years of retirement in order to bridge the gap until State Pension age the size of those withdrawals could affect your future retirement income.

Sequence of returns risk

Sequence of returns risk is the danger that experiencing poor investment returns early in your retirement, combined with ongoing withdrawals, permanently undermines the value of your pension pot even if markets eventually recover.

For example, consider two investors with identical £500,000 starting balances and identical average returns over the course of a 20 year retirement, but different sequences in terms of how those returns are achieved.

Investor A (good early returns): Experiences +10%, +8%, +12% in first three years while withdrawing £20,000 annually. Despite market volatility later, their pot never falls below £450,000.

Investor B (poor early returns): Experiences -15%, -8%, +2% in first three years while withdrawing £20,000 annually. Despite identical average returns to Investor A over the course of 20 years, because this second investor suffered poor returns early on, their pot falls to £380,000 and never fully recovers, running out five years before Investor A's pot.

Mitigation strategies:

• Maintain 2-3 years of withdrawal amounts in cash or short-dated bonds
• Reduce withdrawal rates during down markets if possible
• Consider annuities for essential expenses, keeping only flexible spending in drawdown
• Start retirement with lower equity exposure than during accumulation phase
• Maintain flexible spending budget allowing reductions during market stress

How to plan phased withdrawals

There are a range of financial planning tools you can use for cashflow modelling, which could help you understand how different approaches to pension withdrawals might affect how long your pot could last under a range of different market conditions.

As a general rule of thumb, though, financial advisers often recommend that pension holders keep in mind the "4% rule", which suggests withdrawing 4% of your starting pot annually, adjusting for inflation. While this approach doesn’t guarantee the best return from your pension pot, it does provide a useful starting point for planning.

Example: £500,000 SIPP pot × 4% annual withdrawal = £20,000 withdrawal in the first year, increasing with inflation annually. Historical analysis suggests this approach would sustain most retirees through a 30-year retirement.

Using ISAs and pensions together

ISA vs pension: which one should you draw down first?

If you have both an ISA and a SIPP (and possibly other savings too) then the optimal withdrawal sequence will depend to an extent on your tax circumstances, but generally speaking a good approach might be to:

• Draw taxable accounts first: If you have taxable savings or investments, use these first while remaining within the basic rate tax band, as gains face Capital Gains Tax or income tax anyway.
• Use ISAs for additional income: Once taxable accounts are exhausted, you can withdraw from ISAs before touching pensions, as ISA withdrawals don't count as income for tax and so won't take up any remaining basic rate allowance.
• Preserve pensions longest: It’s typically been a good idea to keep pensions invested the longest, as they’ve offered tax-free growth and favourable inheritance tax treatment, making them valuable for building wealth even during retirement.  However, from April 2027 pensions will become subject to inheritance tax, which will make them much less tax efficient for estate planning (we’ll cover more on this later).

Death Benefits and Passing on Your SIPP

SIPP death benefits provide valuable flexibility for passing wealth to beneficiaries, although tax treatment depends on your age at death and is changing significantly from April 2027.

What happens if I die before 75?

If you’re under 75 when you die, then at present your beneficiaries can inherit your entire SIPP tax-free (within the Lump Sum and Death Benefit Allowance of £1,073,100), making SIPPs extremely tax-efficient for inheritance planning.

Beneficiaries can take funds as lump sums (entire pot immediately, all tax-free, provided it’s below the Lump Sum Allowance and Death Benefit Allowance), through beneficiary drawdown (keeping funds invested, taking income tax-free), or through annuities (buying guaranteed tax-free income).

This generous treatment currently makes a SIPP a valuable tool for estate planning, particularly compared to other assets facing 40% inheritance tax.

However, this is due to change in April 2027, when pensions will become subject to inheritance tax while maintaining their current income tax treatment.

What if I die after 75?

If you’re 75 or older when you die then your beneficiaries pay income tax at their marginal rates on any withdrawals from your SIPP, although at the moment there's no inheritance tax on top of that income tax.

They retain the same flexibility over how to access benefits as death before 75, but all withdrawals face income tax.

From April 2027 pensions will become subject to inheritance tax, which will make them much less tax efficient for estate planning.

Payment options for beneficiaries

Beneficiaries can usually choose how to access inherited SIPPs:

• Lump sum: They can take the entire inherited amount immediately, useful for paying off debts, buying property, or investing outside pensions. This lump sum will be subject to income tax at the beneficiary's rate if the pension holder died after 75.
• Beneficiary drawdown: With this approach, the beneficiary keeps funds invested in the inherited SIPP, taking income as needed while maintaining growth potential and investment control.
• Annuity purchase: The third option is to buy guaranteed income from inherited funds, providing security and certainty for beneficiaries who prefer guaranteed income over investment management responsibilities.

How to nominate beneficiaries

To nominate beneficiaries you should complete your SIPP provider's 'expression of wish' or beneficiary nomination form, clearly specifying your intended beneficiaries. While providers aren't legally bound to follow your wishes (since pension death benefits are usually held under discretionary trust), they typically do unless compelling reasons suggest otherwise.

It’s important to review and update your nominations after major life events including marriage or remarriage, divorce or separation, births of children or grandchildren, deaths of named beneficiaries, and significant wealth or family circumstance changes. Outdated nominations can result in unintended beneficiaries receiving your SIPP, potentially excluding those you wish to benefit and creating family disputes.

From April 2027, new HMRC reporting requirements will apply when pension funds pass to beneficiaries, requiring death benefits to be included in inheritance tax calculations. While this doesn't eliminate pensions' estate planning value, it significantly reduces the inheritance tax advantages that currently exist.

Death Benefit Tax Comparison

Common Mistakes When Accessing a SIPP

Taking too much, too early

Withdrawing large amounts of money from your pension in the early years of retirement can permanently erode your pension pot’s longevity, particularly if markets perform poorly during this same period (the “sequence of returns risk”).

Taking more than you actually need also increases your exposure to inflation, as you'll have less capital that’s still invested to generate growth.

Ignoring tax-band creep

Taking large lump sums without calculating how that income might push you into higher tax brackets means you could accidentally end up paying 40% or even 45% tax on withdrawals that could have been spread across multiple years at just 20% tax.

It's worth modelling your total income, including State Pension, employment income, and other sources, in order to ensure your SIPP withdrawals don't inadvertently trigger higher rate tax charges when phasing them over several tax years would be a better approach.

Accidentally triggering MPAA

Many people don't realise that even small taxable withdrawals from drawdown or taking a single UFPLS payment will permanently trigger the Money Purchase Annual Allowance, reducing their future contribution capacity from £60,000 to just £10,000 for the rest of their life.

If you're still working and contributing to pensions, taking only your 25% tax-free Pension Commencement Lump Sum in the beginning allows you to maintain the full £60,000 Annual Allowance until you actually need more taxable income.

Overlooking death benefit nominations

Failing to update your “expression of wish” form after major life events like marriage, divorce, births, or deaths can result in your SIPP passing to unintended beneficiaries. While SIPP providers typically follow your nominated wishes, outdated forms might still name ex-spouses, exclude new children or grandchildren, or list beneficiaries who've since passed away, potentially creating family disputes and leaving those you intended to benefit without support.

How to Access Your SIPP — Step-by-Step

1. Confirm your age and eligibility: Check you've reached the Normal Minimum Pension Age or have protected pension age rights.
2. Review your pot value and desired access type: Decide whether you want to take your Pension Commencement Lump Sum, move funds into drawdown, take UFPLS withdrawals, or purchase an annuity.
3. Check tax impact and MPAA implications: Model how your withdrawal will affect your tax position and whether it'll trigger the Money Purchase Annual Allowance.
4. Contact your provider or log into your SIPP platform: Initiate the withdrawal process through your provider's chosen method.
5. Select your access route and request withdrawal: Complete the necessary forms and specify the amount and method of withdrawal.
6. Receive funds and monitor your tax code: Check that PAYE has been applied correctly and reclaim any overpaid tax if emergency codes were used.
7. Update your records, review your portfolio, and plan the next phase: Keep track of your remaining allowances, adjust your investment strategy if needed, and plan future withdrawals.

Frequently Asked Questions on Accessing a SIPP

What is the minimum age to access a SIPP?

The minimum age to access your SIPP is currently 55, although that's rising to 57 from 6th April 2028. Early access is only permitted in very exceptional circumstances, such as serious ill health with a life expectancy of less than 12 months, or ill health that isn’t terminal but where you’re unable to work anymore.

Can I take 25% of my SIPP tax-free?

Yes, you can take up to 25% of your SIPP as tax-free cash (known as the Pension Commencement Lump Sum), subject to the Lump Sum Allowance of £268,275. You can take this all at once or phase it gradually over time as you crystallise different portions of your SIPP.

What is the difference between drawdown and UFPLS?

With flexi-access drawdown, you designate funds for retirement income while keeping them invested, giving you control over withdrawal amounts and timings.

With UFPLS (Uncrystallised Funds Pension Lump Sum), you take lump sums directly from your uncrystallised SIPP, with 25% of each withdrawal being tax-free and 75% taxable.

The key difference between the two is that drawdown requires formal crystallisation first, while UFPLS provides ad-hoc access without this step, although both trigger the MPAA when you actually withdraw taxable income.

How much tax will I pay when accessing my SIPP?

Your tax-free 25% Pension Commencement Lump Sum isn't taxed, but the remaining 75% is taxed as income at your marginal income tax rate (20%, 40%, or 45%). In practice, that means the amount of tax you pay on that 75% portion of your SIPP will depend on your other income, including other pensions, employment, self-employment or consulting, rental income if you own property, and other investment income.

Your SIPP provider operates PAYE and deducts tax before paying you, although you won't pay National Insurance on pension withdrawals.

Can I take money out of my SIPP before age 55?

You can only access your SIPP before age 55 in very exceptional circumstances, such as if you have a terminal illness with a life expectancy of less than 12 months, or if ill health means you’re no longer able to work even if the condition isn’t terminal.

Accessing your pension early without meeting these criteria results in a 55% unauthorised payment charge from HMRC, plus potentially a 40% surcharge, which can exceed 100% of the amount withdrawn.

What happens to my SIPP when I die?

If you die before the age of 75, your beneficiaries can currently inherit your SIPP tax-free (within the Lump Sum and Death Benefit Allowance of £1,073,100). If you die after 75, your beneficiaries will pay income tax at their marginal rate on withdrawals.

However, from April 2027 pensions will become subject to inheritance tax regardless of your age at death, significantly reducing their inheritance tax advantages.

What is the MPAA and how does it affect contributions?

The Money Purchase Annual Allowance (MPAA) reduces your Annual Allowance from £60,000 to £10,000 once you start taking flexible pension benefits like drawdown income or UFPLS. This restriction is permanent and applies for the rest of your life. However, taking only your 25% tax-free cash or buying a lifetime annuity doesn't trigger the MPAA, since that tax-free amount isn’t treated as flexible access.