Roth Disability Distribution

How would you process a Roth direct distribution due to disability? My original thought was that it should be code "B" and "3", but the 1099-R instructions state that code 3 can only be used with one other code ("D").

Thank you.

Vlad401k, you will notice that the 1099-R instructions are (still) very cryptic regarding Code 3. They really only reference the disability standard involved, not when you use Code 3. My guess is that you are supposed to use it only if the distribution event is disability, e.g. in a DB plan with an actual disability benefit (as opposed to a benefit, e.g. in a DC plan, which is permissible because of the participant's termination on account of disability).

Presumably, you are trying to get the disability exception to pre-59-1/2 for having a qualified distribution for Roth and no 72(t) premature distribution tax (which would only apply if you didn't have a qualified distribution). Note that the last bullet in the instructions for Code 2 is inclusive of 72(t)(2)(A)(iii). I would probably go with 2B.