No. QCDs can be made only from traditional IRAs and traditional inherited IRAs. (If making a QCD from an inherited IRA, the client would still need to be age 70½ to qualify.)
To be eligible to make a QCD from an inherited/beneficiary traditional IRA, the beneficiary must be age 70½ or over at the time of the distribution. The age of the decedent does not matter.
(Specifically, to make a QCD, the one for whom the IRA is maintained must be age 70½ or over at the time of the distribution. In the case of a BDA IRA, the one for whom the IRA is maintained is the beneficiary.)
I would dearly love to know what NSPS stands for. The answer appears not to exist on my version of the internet, although it DOES appear on my investment statement.
My guess is that it is referring to a non-spouse beneficiary, but it's irrelevant with regard to making a QCD. To make a QCD, the one for whom the IRA is maintained must be age 70½ or over.
Yes, I was thinking it was "Non-Spouse Something Something." My actual question is more curiosity about the abbreviation than the original posted question. This thread is one of the very few internet search hits I found that even includes NSPS in the context of investing/banking!
Thx!