Help! I have a client that had her funds in a TSP as a gov’t employee. TheTSP would not transfer funds into an annuity even after several attempts to get their (The TSP’s) paperwork accurate. The funds were eventually transferred into a newly created IRA at a bank to accept the funds. The client then wrote a check on that IRA account to place the funds into her originally desired annuity.

My understanding is, that Because the original funds did NOT come from a prior IRA, and it was a direct transfer, does writing the check to an annuity violate the 365-day rollover-rollover rule. Am I correct? Thank you!