QCD for Split-Interest Entity

Does anyone have an opinion on whether the SECURE 2.0 one-time $50,000 QCD to a split-interest entity counts against the overall $100,000 annual limit?

Seems to me that the legislation doesn't clearly answer that question.

Internal Revenue Code § 408(d)(8)(F)(i) states a general rule that “[a] taxpayer may for a taxable year elect under [§ 408(d)(8)(F)] to treat as meeting the requirement of [§ 408(d)(8)(B)(i)]” an IRA’s distribution to a split-interest entity.

Internal Revenue Code § 408(d)(8)(B)(i) defines a qualified charitable distribution as an IRA’s distribution made to specified kinds of public charities.

The statute sets up direct and indirect distributions to charity.

I read the statute to apply the § 408(d)(8)(A) [$100,000] limit to the sum of all qualified charitable distributions of both ways.

https://irc.bloombergtax.com/public/uscode/doc/irc/section_408