As I turn 70 1/2 this year, the question is of more than academic interest to me. For those DA readers at or nearing RMD territory, it's an issue which might be worthy of inquiry.
Background: In the year a person attains the age of 70 1/2, RMDs of IRAs must commence. The IRS allows the RMD to be satisfied by a withdrawal from one IRA account, or multiple accounts. Many financial institutions waive the EWP on partial, early, withdrawals on IRA CDs for RMDs. They may, or may not, waive the EWP as to that portion of a RMD not attributable to your IRA CD with them. A few financial institutions allow partial withdrawals from IRA CDs with no EWP for those over age 59 1/2. This is generally called a "normal" distribution. As far as I know, you can satisfy your RMD with a normal distribution.
Example: Jack has an IRA CD with XYZ credit union. The Truth-in-Savings Disclosure provides that EWPs will be waived for RMDs. Jack has $1,000,000 total in IRA accounts (stocks, bonds, CDs) and wants to satisfy his $36,400 RMD by a partial withdrawal on his IRA CD at XYZ. His IRA at XYZ is in the amount of $50,000. Will Jack be hit with an EWP?
Analysis: He might, notwithstanding the broad language in the TiS Disclosure. The credit union could take the position the waiver language applies only to the RMD directly attributed to Jack's IRA CD at XYX. He could withdraw $1820 without EWP; beyond that he could be socked with an EWP, or even told a partial withdrawal in the amount he seeks is not allowed.
What's Plan B?: Fortunately, Jack also has IRA CDs with StateFarmBank and PenFed. Each allows (subject to the standard "we may" permit caveat) partial withdrawals from IRA CDs after age 59 1/2 with no EWP. Jack has a $50,000 IRA CD with SFB and another $50,000 IRA CD at PenFed. Jack can satisfy his RMD by a partial withdrawal from either, or both, with no EWP.
Bottom Line: When mapping out any RMD strategy where IRA CDs might or will be used as a funding source. make sure your assumptions and the financial institution's policies are consistent. If the language in the TiS Disclosure is a tad vague (rest assured, it might well be), set forth your intentions in writing, and get clarification in writing. Then, in an over-abundance of caution, have a Plan B, like Jack.
PS: Credit to the DA poster who raised this issue some time ago (whose posting handle I forget; my apologies).