New 1099-R Coding for QCD's

[TaxGuyBill]

So if the money was not paid to the IRA account owner, nor to another IRA custodian, nor to the IRS or some other government agency under a court order, then it's pretty clear it's a QCD,

If I have an IRA-checkbook and I write the check to Rapid Robert, are you saying they should assume it is an QCD? Or do you assume that the bank should research if Rapid Robert is a 501(c)(3)? Or what if I write the check to 'My Bank' - does the IRA custodian know if I deposited it into my personal bank account or if it deposited it into a rollover IRA account?

In my opinion, the IRA custodian should NOT assume any of those and should be treated as a taxable/non-rollover distribution. It should still be an option for the taxpayer to state if it was a qualifying QCD or not.